UNITED STATES OF AMERICA v. DESHAWN DOZIER
US Court of Appeals for the Fourth Circuit, Davis, Jan. 30, 2017,
Sentencing – Career Offender- A West Virginia conviction for attempted cocaine distribution can be used as a predicate for a Career Offender sentence enhancement
UNITED STATES v. MICHAEL BRYANT, JR.
Supreme Court of the United States, Ginsburg, June 13, 2016,
Enhanced Sentence – Because the Sixth Amendment doesn’t apply to tribal court proceedings, valid underlying convictions from trial court can serve to enhance federal sentences even where they are obtained without right to counsel
(Concur – Thomas – Prior convictions violating Sixth Amendment should be used for enhancement, Indian Affairs shouldn’t be subject to blanket congressional oversight without at least considering the tribes individually and the treaties made)