United States v. Diaz, No. 10-50029 (9th Cir. 2016)
Annotate this CaseJesse Vasquez was convicted of drug-related crimes for his part in a gang's drug trafficking operations. The district court sentenced Vasquez to life imprisonment because his two prior California felonies qualified him for a mandatory sentence enhancement under 21 U.S.C. 841. Vasquez then successfully petitioned a California court to reclassify one of his prior California felonies as a misdemeanor pursuant to Proposition 47. In this appeal, Vasquez argues that his federal enhancement should be invalidated because he no longer stands convicted of two prior felonies as section 841 requires. The court has previously held that a state granting postconviction relief from a state conviction cannot undermine a federal sentence enhancement based on that conviction. The court has upheld this rule even where a state dismisses or expunges the underlying state conviction the federal enhancement is based on. Therefore, the court affirmed Vasquez's sentence of life imprisonment under section 841.
Court Description: Criminal Law. The panel affirmed a sentence of life imprisonment mandated under 21 U.S.C. § 841 because of the defendant’s two prior felony drug convictions. Four years after his sentencing, California adopted Proposition 47, which allows California courts to reclassify certain felony convictions as misdemeanor convictions, and the defendant successfully petitioned a California court to reclassify one of his prior California felonies—on which his federal enhancement was based—as a misdemeanor. The panel held that Proposition 47 does not undermine a prior conviction’s felony-status for purposes of § 841. The panel explained that § 841 requires looking to the status of the defendant’s state conviction when he was convicted of his federal crime—and as of that day, the defendant was “convict[ed] for a felony drug offense” as § 841 requires. The panel addressed other issues in a concurrently-filed memorandum disposition. 6 UNITED STATES V. DIAZ
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