U.S. v. Craft

Defendant pleaded guilty to one count of conspiracy to distribute methamphetamine and was sentenced to 150 months in prison followed by five years of supervised release. In calculating the sentence, the district court applied two sentencing enhancements, including the premises enhancement. The Seventh Circuit held that the trial court erred in applying the premises enhancement, because the record did not support the trial court’s conclusion that the defendant used his home for the primary or principal purpose of manufacturing or distributing drugs and remanded for re-sentencing. (WOOD and ST. EVE, concurring)