United States v. Castellanos Muratella, No. 19-1219 (8th Cir. 2020)
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The Eighth Circuit affirmed defendant's sentence for participating in a methamphetamine-distribution conspiracy. The court held that the district court correctly designated defendant as a career offender based on his prior conviction for two felony drug crimes under Iowa Code section 124.401. The court held that section 124.401 is no broader than USSG 4B1.2.
The court also held that the district court did not abuse its discretion in sentencing defendant where there was no indication that the district court counted his methamphetamine addiction against him. Rather, the generous variance suggests just the opposite. Therefore, defendant's sentence was not substantively unreasonable.
Court Description: [Grasz, Author, with Benton and Stras, Circuit Judges] Criminal case - Sentencing. The district court did not err in determining defendant was a career offender based on his Iowa convictions for violation of Iowa Code 124.401, as the Iowa law is no broader than Guidelines Sec. 4B1.2; the sentencing record and defendant's below-guidelines sentence do not support his claim that the court failed to consider - or held against him - his drug addiction, and the claim that his sentence was substantively unreasonable is rejected.
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