United States v. Capelton, 966 F.3d 1

Jerome Capelton was convicted in federal court (2001) for crack-cocaine offenses; his original sentence used the career-offender Guideline (§4B1.1) based on two Massachusetts prior felony drug convictions (1992 possession with intent; 1996 distribution).
After the First Step Act, Probation recalculated sentencing ranges; career-offender status still applied and produced a Guidelines range of 262–327 months; district court sentenced Capelton to 252 months after a 10-month variance.
Capelton argued at resentencing (and on appeal) that his two Massachusetts predicates were categorically overbroad because, at the time of those convictions, Massachusetts "joint venture" (accomplice) liability allegedly permitted conviction on mere knowledge rather than the shared intent required by the generic aiding-and-abetting standard.
The district court rejected that theory as unrealistic, concluding Massachusetts law required shared intent; it retained the career-offender enhancement and imposed the revised sentence.
On appeal, the First Circuit reviewed the career-offender determination de novo, assumed arguendo the parties’ framing of the categorical approach, and held that Massachusetts required shared intent for joint venture liability during the relevant period, so the priors qualified as "controlled substance offense[s]."

Issue	Plaintiff's Argument (Capelton)	Defendant's Argument (Government)	Held
Whether Capelton's 1992 and 1996 MA drug convictions are categorically "controlled substance offense[s]" for §4B1.1 because MA joint venture allegedly allowed conviction on mere knowledge	MA joint-venture/accomplice doctrine then allowed conviction on proof of knowledge alone, broader than generic aiding-and-abetting (which requires shared intent), so priors are overbroad and cannot serve as predicates	Massachusetts law required shared intent for joint venture; priors therefore match the generic aiding-and-abetting definition and qualify as controlled-substance offenses	Court held Massachusetts joint-venture law required shared intent in the relevant period, so the priors qualify and career-offender designation stands
Whether any procedural waiver or harmlessness bars relief	(Argued in part) Even if claim not waived, merits control	Government also argued waiver and harmlessness (e.g., supervised-release consequences)	Court declined to resolve waiver/harmlessness because it rejected the merits; affirmed sentence

Taylor v. United States, 495 U.S. 575 (establishing the categorical approach for prior-offense matching)
Moncrieffe v. Holder, 569 U.S. 184 (requirement of a "realistic probability" the state would apply statute to conduct outside the generic definition)
Mathis v. United States, 136 S. Ct. 2243 (limits on examining state-law conduct under the categorical approach)
Rosemond v. United States, 572 U.S. 65 (federal standard on aiding-and-abetting mens rea requiring purposeful participation)
Commonwealth v. Soares, 387 N.E.2d 499 (Mass. SJC articulation that joint enterprise requires sharing the mental state of the principal)
Commonwealth v. Bianco, 446 N.E.2d 1041 (Mass. SJC three-part formulation of joint-venture liability used during the relevant period)
Commonwealth v. Zanetti, 910 N.E.2d 869 (Mass. SJC reformulation/clarification of jury instructions clarifying that joint venture requires the intent required for the substantive offense)
United States v. Benítez-Beltrán, 892 F.3d 462 (1st Cir.) (noting Application Note 1 includes aiding-and-abetting within §4B1.2)
United States v. García-Cartagena, 953 F.3d 14 (1st Cir.) (application of the categorical approach to Guidelines predicate determinations)