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| Drug Trafficking Offense |
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United States v. Morales-Martinez,
No. 06-40467 (5th Cir., August 8, 2007): Federal Sentencing Guidelines; Drug Trafficking Offense: A state court conviction for delivery of cocaine was not a prior "drug trafficking offense" under the Guidelines.
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United States v. Torres-Romero,
No. 07-1421 (10th Cir., August 19, 2008) (Published): Federal Sentencing Guidelines; Drug Trafficking Offense: Sixteen level enhancement AFFIRMED because prior state conviction was a "drug trafficking offense" according to the material facts in the charging information. Judge Hartz dissented on the basis that the information charged several means of committing the same offense and that additional evidence would be required to establish a drug trafficking offense.
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