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Home / Opinions / Courts / 8th U.S. Circuit Court of Appeals / Criminal Law: Drug Offenses-Safety-Valve Relief-Incomplete Proffer

Criminal Law: Drug Offenses-Safety-Valve Relief-Incomplete Proffer

Defendant appealed his sentence, arguing the district court erred in finding that his proffer to the government was not complete and truthful to entitle him to safety-valve relief for his various drug offenses.

Where the government’s evidence suggested defendant had a larger role in the drug-distribution conspiracy than he admitted to and where defendant failed to establish that he provided complete information, the district court was justified in denying safety-valve relief.

Judgment is affirmed.

U.S. v. Valquier (MLW No. 73786/Case No. 18-1466 – 4 pages) (U.S. Court of Appeals, 8th Circuit, Melloy, J.) Appealed from U.S. District Court, District of Nebraska, Rossiter, J. (Kate Ono Rahel, of Omaha, NE for appellant;  Jason E. Troia, of Omaha, NE on brief) (Patrick C. McGee, AUSA, of Omaha, NE for appellee)