Federal 7th Circuit Court
Criminal Court
Ineffective Assistance of Counsel
In sentencing proceeding in which defendant received 181-month term of incarceration on multiple narcotics and weapons charges, defendant's counsel was not ineffective for failing to object to two-level enhancement based on defendant's possession of .22-caliber rifle with obliterated serial number, even though govt. could not establish that said rifle had ever moved in interstate commerce. No error occurred where ability to enhance defendant's sentence based on uncharged conduct does not turn on whether said conduct could have been prosecuted in federal court, and record otherwise contained meaningful link between defendant's possession of rifle, which was located near drugs, and instant charged offenses.