U.S. v. Spiller

Dist. Ct. did not err in sentencing defendant to 240-month term of incarceration on drug and firearm charges, even though defendant claimed that Dist. Ct. did not adequately address his main mitigation argument that he was entitled to reduced sentence because he had unreasonably inflated sentencing range caused by application of section 851 recidivism enhancement. Defendant properly qualified for section 851 enhancement based on his prior felony convictions, and record showed that Dist. Ct. implicitly considered defendant’s mitigation argument after noting that longer sentence was required due to defendant’s extensive criminal history.