United States v. Benton

The Eighth Circuit affirmed defendant's sentence as a career offender after he pleaded guilty to one count of possession of methamphetamine with intent to distribute. The court held that defendant's prior Louisiana drug conviction qualified as a predicate conviction for career offender sentencing under USSC 4B1.1(a). On this record, the court held that it was no more likely that defendant was convicted of simple possession of cocaine than it was he was convicted of possession with intent to distribute. The court also held that the district court's failure to inquire into the Louisiana conviction was clearly or obviously wrong in the absence of controlling precedent requiring district courts to sua sponte confirm the accuracy of the PSR's description of the defendant's prior convictions. View "United States v. Benton" on Justia Law