UNITED STATES OF AMERICA v. BRADFORD D VOL ALLEN
US Court of Appeals for the Fourth Circuit, Keenan, November 28, 2018,
Sentencing – Use of a communication facility in a drug-trafficking crime qualifies as a “controlled substance offense” for sentencing enhancement purposes

USSG – Guidelines commentary is authoritative and controlling unless it 1) “violates the Constitution or a federal statute;” 2) “is inconsistent with” the Guidelines; or 3) constitutes a “plainly erroneous reading” of the Guidelines