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Criminal Law-Drug Offense-Career Offender Designation-Predicate Offense
Staff Report//May 13, 2026//
Defendant appealed the sentence imposed following his guilty plea to drug offenses, challenging the use of a prior assault offense as a predicate for his career offender designation because the assault conviction arose from a nolo contendere plea.
Where defendant’s argument was foreclosed by circuit precedent, the court affirmed defendant’s sentence.
Judgment is affirmed.
U.S. v. Holt (MLW No. 84755/Case No. 24-2346 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of North Dakota, Hovland, J.
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