Fifth Circuit - Relevant Conduct

United States v. Horton, 993 F.3d 370 (5th Cir. 2021). The defendant’s two prior state drug-related convictions were criminal history and not relevant conduct to his federal offense of possession of methamphetamine with the intent to distribute. One state offense was possession of a small amount of methamphetamine, possibly for personal use, and the other was possession of paraphernalia.

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