United States v. Brown, No. 20-1512 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to distributing cocaine base, and possessing controlled substances with intent to manufacture and distribute at least 280 grams of cocaine base. The court concluded that there was no error in applying the USSG 4B1.1 career offender enhancement because defendant's prior Iowa conviction for attempted murder qualified as a crime of violence and his Iowa drug conviction constituted a qualifying controlled substance offense. The court also concluded that defendant's 240-month sentence was not substantively unreasonable where the district court had wide latitude to consider the 18 U.S.C. 3553(a) factors and did not abuse its discretion.
Court Description: [Per Curiam - Before Smith, Author, and Kelly and Erickson, Circuit Judges] Criminal case - Sentencing. The district court did not err in applying a Section 4B1.1 career-offender enhancement as defendant's Iowa attempted murder conviction qualified as a crime of violence and his Iowa drug conviction constituted a qualifying controlled substance offense; defendant's 240-month sentence was not substantively unreasonable.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.