United States v. Bolton

Defendant appealed his consolidated sentence for his marijuana distribution and cocaine distribution convictions in two separate cases. The Fourth Circuit held that the district court did not err by imposing the firearm enhancement where defendant failed to show by a preponderance of the evidence that the firearms were not connected to his drug distribution. Even if the district court erred by assuming it could not grant a safety valve reduction because of the firearm enhancement, any such error was harmless. The court also held that the district court did not err in refusing to reduce defendant's offense level for acceptance of responsibility, and defendant's sentence was substantively reasonable even if the district court varied upward from defendant's Guidelines range by 40 months. Accordingly, the court affirmed the judgment. View "United States v. Bolton" on Justia Law