United States v. Winfield

These consolidated appeals raise a single issue: whether the district court erred by adjusting Paul Winfield’s offense level upwards based on the court’s finding that Winfield “maintained” his apartment for distributing controlled substances, see U.S.S.G. § 2Dl.l(b)(12). Winfield argues that the guideline doesn’t apply here because drug dealing was not among his “primary or principal” uses for the apartment, see U.S.S.G. § 2D1.1 cmt. n.17. We disagree and affirm the district court’s judgments.

A police informant bought heroin and methamphetamine from Winfield during four controlled buys…