United States v. Stewart, No. 13-10048 (9th Cir. 2014)
Annotate this CaseDefendant appealed his sentence after pleading guilty to two counts of distributing a controlled substance. Defendant argued that the Sentencing Commission exceeded its authority under 28 U.S.C. 994(h) by including state convictions as predicate offenses for purposes of defining a career offender, and that his sentence was substantively unreasonable because of the very low purity of the controlled substance he sold and the career offender guidelines' over-representation of his criminal history. The court concluded that the Sentencing Commission's career offender guidelines are a permissible interpretation of the relevant statutes; the district court was mistaken about the impact of the purity of the controlled substance, but defendant's sentence was nonetheless reasonable under the totality of the circumstances; and, therefore, the court affirmed the judgment of the district court.
Court Description: Criminal Law. Affirming a sentence for distributing a controlled substance, the panel reaffirmed this court’s holding that because 18 U.S.C. § 944(h) does not limit career offender status under the Sentencing Guidelines to defendants with two predicate federal convictions, the Sentencing Commission did not exceed the scope of its delegated authority by including prior state convictions as an additional basis for career offender status. The panel also held that the district court was mistaken about the impact of the purity of the controlled substance, but that the defendant’s sentence was nonetheless reasonable under the totality of the circumstances.
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