Keys v. United States, No. 18-2537 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate, set aside, or correct his sentence under 28 U.S.C. 2255. The court held that Application Note 8 to USSG 1B1.3 foreclosed petitioner's argument that his 2008 and 2009 Iowa drug convictions were relevant conduct to the federal offense of conviction. The court explained that Application Note 8 plainly provides that prior criminal conduct for which a sentence was imposed before the conduct charged in the indictment is not relevant conduct. The court need not determine whether the district court erred in finding that it was unclear whether petitioner's proffer interview supported his argument.
Court Description: Shepherd, Author, with Benton and Grasz, Circuit Judges] Prisoner case - Section 2255. Application Note 8 of the Guidelines regarding prior criminal conduct foreclosed Keys' sentencing argument, and the court need not determine whether the district court erred in finding it was unclear whether Keys' proffer interview supported his argument.
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