Tenth Circuit, Joining Sister Circuits, Announces ‘Personal-Use’ Drug Quantity Doesn’t Constitute ‘Relevant Conduct’ Under Guidelines § 1B1.3(a) and Sets Forth Framework for Burden of Proof Analysis by Douglas Ankney by Douglas Ankney  In a case of first impression, the U.S. Court of Appeals for the Tenth Circuit adopted the burden-shifting …

Eleventh Circuit Announces Drug Offenses Involving Multiple Drugs Can Qualify as ‘Covered Offense’ Under First Step Act if Crack One of the Drugs by Dale Chappell by Dale Chappell The U.S. Court of Appeals for the Eleventh Circuit held on December 9, 2020, that as long as one of the …