United States v. Trent, No. 20-1539 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit reversed defendant's 51-month sentence imposed after the district court determined that he had violated the conditions of his supervised release. While defendant was awaiting a hearing on his alleged violations of his supervised release, law enforcement discovered that he was in possession of 4.86 grams of cocaine. In this case, defendant stipulated that he violated his conditions of release by possessing cocaine, but he denied that he intended to distribute a controlled substance. Furthermore, the district court did not find that defendant had committed a controlled substance offense as that term is defined in the Sentencing Guidelines. Therefore, the district court erred by concluding that defendant had committed three grade A violations and the court remanded for resentencing.
Court Description: [Per Curiam - Before Smith, Chief Judge, with Kelly and Erickson, Circuit Judges] Criminal case - Sentencing. In this revocation proceeding,defendant only stipulated that he possessed cocaine and denied that he intended to distribute a controlled substance; the district court did not find that he committed a controlled substance offense as that term is defined in the Guidelines, and it was error to find that defendant committed three Grade A violations; reversed and remanded for resentencing.
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