United States v. Emanuel Brown, United States of America v. Emanuel Brown
Court of Appeals for the Fourth Circuit
1Opinion of the Court
Vacated and remanded by published opinion. Senior Judge BUTZNER wrote the opinion, in which Judge NIEMEYER and Senior Judge JOSEPH H. YOUNG joined.
OPINION
BUTZNER, Senior Circuit Judge:
Emanuel Brown pleaded guilty to a single count of distributing crack cocaine in violation of 21 U.S.C. § 841(a)(1). During sentencing, the district court classified Brown as a career offender because he had two prior felony controlled substance convictions in the District of Columbia. The court then departed downward because it found that one of Brown’s convictions involved a small quantity of drugs.
The United…
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