United States v. Tracy Fells
Court of Appeals for the Fourth Circuit
1Opinion of the Court
WILKINS, Circuit Judge:
Tracy Fells appeals his conviction and sentence for five counts of distribution of crack cocaine. 21 U.S.C.A. § 841(a)(l)-(2) (West 1981). Fells contends that the district court erred in admitting into evidence the details of conversations between Fells and undercover agents that occurred after he committed the charged offenses. He also argues that the district court improperly increased his offense level by 4 based on his role as an organizer of a criminal activity that involved five or more participants.
I
During an investigation of illicit drug transactions in the…
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