United States v. Brown

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The Ninth Circuit vacated defendant's 60-month sentence for being a felon in possession of a firearm and remanded for resentencing. The panel held that defendant's previous conviction for drug conspiracy under Washington state law did not qualify as a controlled substance offense because the Washington drug conspiracy statute was not a categorical match to conspiracy under federal law. Therefore, the district court erred when calculating defendant's Sentencing Guidelines range and the error was not harmless. View "United States v. Brown" on Justia Law