U.S. v. Reeves

Dist. Ct. did not err in sentencing defendant to 25-year term of incarceration on drug conspiracy charges based, in part, on finding that defendant qualified for sentencing enhancement under 21 USC section 851 arising out of 2004 state court conviction on drug charges to which defendant had pleaded guilty. While defendant argued that enhancement was improper since his trial counsel during 2004 guilty plea proceedings had failed to inform him that guilty plea could be used to trigger sentencing enhancement in any subsequent conviction, Ct. found that it was not unreasonable for defendant's counsel to fail to give said advice where possibility of enhancement was entirely contingent on defendant's decision to commit additional crimes.