Criminal Law: Sentencing-Felony Drug Offense-Prior Conviction

Where a defendant argued that a California conviction did not qualify as a prior conviction for a “felony drug offense” as required for an enhanced sentence, the California conviction qualified as a “felony drug offense” even though the offense was later re-designated as a misdemeanor, so the judgment is affirmed.

Judgment is affirmed.

U.S. v. Santillan (MLW No. 74248/Case No. 18-3182 – 5 pages) (U.S. Court of Appeals, 8th Circuit, Shepherd, J.) Appealed from U.S. District Court, Northern District of Iowa, Reade, J. (Raphael M. Scheetz, Cedar Rapids, Iowa, argued for appellant) (Shawn Wehde, Sioux City, Iowa, argued for appellee).