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Criminal Law: Possession with Intent to Distribute-Safety Valve Relief-Eligibility

Staff Report//July 9, 2026//

Criminal Law: Possession with Intent to Distribute-Safety Valve Relief-Eligibility

Staff Report//July 9, 2026//

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Defendant appealed the sentence imposed following his guilty plea to possession with intent to distribute, arguing that the district court erred in finding him ineligible for safety valve relief because other conduct was relevant conduct to the offense, he possessed multiple firearms, and he was an organizer, leader, manager or supervisor. Defendant also challenged the application of “dangerous weapon” and “aggravating role” enhancements.

Where the district court expressly stated that it would have imposed the same sentence absent the determinations challenged by defendant, any error was harmless.

Judgment is affirmed.

U.S. v. Cox (MLW No. 85053/Case No. 25-1770 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Arkansas, Hickey, J.

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