U.S. v. Purham

Dist. Ct. erred in sentencing defendant to 360-month term of incarceration on drug conspiracy charge arising out of conduct that occurred in 2010, where said sentence was based in part on relevant conduct finding that included defendant’s conduct in transporting 1.8 kilograms of crack cocaine in 2008. Record failed to contain sufficient connection between defendant’s 2008 conduct and his 2010 drug conduct that formed basis of instant charged offense, where fact that defendant transported crack cocaine in both 2008 and 2010 was only similarity in conduct. Moreover, record failed to contain sufficient details with respect to mode of transportation and quantities of crack cocaine so as to establish “strong showing” of similarity for acts that occurred two years apart. Fact that 2008 and 2010 conduct involved members of same gang did not require contrary result.