United States v. Jerome Jackson, 425 F. App'x 476

Jackson was convicted of distributing at least five grams of cocaine base based on a controlled buy in a Chattanooga hotel.
Police used video of the transaction; the cooperating source purchased crack cocaine with prerecorded buy money and Jackson left briefly before returning with a bag containing 11.05 grams of cocaine base.
The cooperating source later faced murder charges, prompting a government in limine motion to bar references to any crimes by the source; the court allowed cross-examination about the source’s motivations but not about the murder charge as it would prejudice.
Jackson was sentenced under the Guidelines as a career offender with an offense level of 34 and a criminal history category VI, yielding a 262–327 month range; he received a 290-month sentence.
On appeal, Jackson challenged confrontation rights, sentencing procedure, speedy-trial delay, and sufficiency of drug quantity evidence; the panel affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confrontation rights and cross-examination limits	Jackson argues Langford’s cross-examination about the informant’s murder charge violated confrontation.	Jackson contends the informant’s murder charge undermines Langford’s credibility and testimony.	No Sixth Amendment violation; limits were proper and harmless.
Jury trial rights and advisory guidelines	Jackson claims the Guidelines and criminal history used to enhance him deprived his jury-trial rights.	Jackson asserts the district court erred by treating guidelines as mandatory and relying on career-offender status.	Waived and, in any event, sentence within Guidelines is reasonable.
Speedy Trial Act (pre-indictment delay)	Jackson contends pre-indictment delay violated the Speedy Trial Act.	Delay was improper timing and unconstitutional.	Waived and, on merits, state custody time does not count toward federal Speedy Trial Act clock.
Sufficiency of drug-evidence weight	12.2 grams claimed in PSR; argues insufficiency due to fragmented crack cocaine and jury not weighing crack separately.	Evidence showed 11.05 grams of cocaine base; proper weight established by lab testimony.	Sufficient evidence; 11.05 grams supports conviction beyond a reasonable doubt.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause and testimonial evidence)
Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (Cross-examination to test witness credibility)
Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (Limits on cross-examination; prejudice concerns)
Stewart v. Wolfenbarger, 468 F.3d 338 (6th Cir. 2006) (Confrontation analysis for limited cross-examination)
Boggs v. Collins, 226 F.3d 728 (6th Cir. 2000) (Confrontation-rights standard in limiting cross-examination)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (Quantity-related enhancements must be proven beyond a reasonable doubt)
United States v. Haney, 23 F.3d 1413 (8th Cir. 1994) (Crack cocaine weight and handling considerations)