United States v. Clayborn, No. 19-1291 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed defendant's conviction as a career offender under USSG 4B1.1 based on his controlled substance convictions in Illinois and in Iowa. The court held that the district court did not err in concluding that defendant's Iowa and Illinois controlled substance convictions qualified as predicates for career offender sentencing. The court declined to find that the Illinois and Iowa statutes are categorically not career-offender predicates because they include the word "deliver," which may not involve a commercial activity; the Illinois and Iowa convictions are not overbroad; and defendant's remaining claims to the contrary were rejected.