U.S. v. Isom

Dist. Ct. did not err in sentencing defendant to 261-month term of incarceration on drug distribution charges after attributing 537.38 grams of cocaine base as uncharged relevant conduct based on testimony of police officer who relayed statements of two individuals who claimed that they had made series of purchases of cocaine base from defendant. Ct. rejected defendant's arguments that Dist. Ct. should have presumed that instant hearsay statements from said individuals were unreliable since they were non-testifying co-conspirators, and instead found that said presumption, while valid for similar testimony offered during trial, was not applicable to instant statements admitted during sentencing proceeding. Moreover, subject statements were reliable given fact that said statements were consistent with other statements given to police, and that one individual made unrebutted claim that she was frequent customer of defendant.