Criminal Law-Drug Distribution-Guidelines Calculation-Downward Variance

Staff Report//January 7, 2026//

Staff Report//January 7, 2026//

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Defendant appealed the sentence imposed following his guilty plea to drug distribution. The district court calculated the Guidelines range but varied downward. Defendant argued that the district court erred in its Guidelines calculation because his prior offenses were too remote to constitute the same course of conduct and imposed too long of a sentence as a result.

Where defendant was on pre-trial release for his prior offenses when he engaged in the present drug trafficking offense, there was no error in concluding that defendant was continuing to deal drugs as part of the same course of conduct.

Judgment is affirmed.

U.S. v. Skinner (MLW No. 84172/Case No. 24-2525 – 6 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Eastern District of Arkansas, Baker, J.

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