United States v. Bell, No. 10-4644

Decided Dec. 21, 2011

Appellants Nancy Bell and Iris Gibson, Bell’s daughter, pled guilty to several counts arising out of a conspiracy to distribute oxycodone pills. On appeal, they challenge the drug quantities from which the district court calculated their base offense levels under the Sentencing Guidelines, primarily because (1) Bell obtained the pills with a valid prescription and consumed some of the pills herself, and (2) the evidence of actual drug trafficking consisted of co-conspirator testimony of uncertain reliability. The Fourth Circuit Court of Appeals vacated the judgments and remanded for resentencing because the district court failed to explain adequately its methodology for calculating the drug quantity or otherwise to make findings sufficient to permit appellate review of the sentences for procedural reasonableness.

Full Opinion

-Sara I. Salehi

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