United States v. Nashaun Drake, 126 F.4th 1242

Nashaun Drake was investigated for drug trafficking in Euclid, Ohio, and police found large quantities of fentanyl, cocaine, and methamphetamine in his apartment.
Drake pleaded guilty to five counts of drug possession with intent to distribute under federal law.
At sentencing, the district court declared Drake a “career offender,” largely based on a prior 2016 Ohio conviction for marijuana trafficking.
The resulting guideline range was 188–235 months, and Drake was sentenced to 200 months in prison.
On appeal, Drake argued: (1) his prior conviction should not trigger the career-offender enhancement, and (2) his sentence was substantively unreasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Career-offender enhancement	2016 marijuana conviction shouldn't qualify since the statute then covered hemp, which is now legal	Enhancement should apply; relevant drug schedules are those at the time of the conviction (2016)	Enhancement properly applied; time-of-conviction rule controls
Substantive reasonableness	Sentence failed to give enough weight to mitigating facts like childhood abuse and mental condition	Sentence was appropriate due to criminal history, risk to public, prior lenient sentences were ineffective	Sentence was reasonable; district court properly exercised discretion

United States v. Clark, 46 F.4th 404 (6th Cir. 2022) (adopts time-of-conviction standard for controlled substance offenses in career offender enhancements)
Gall v. United States, 552 U.S. 38 (2007) (sets standard of review for reasonableness of sentences under federal law)
Brown v. United States, 602 U.S. 101 (2024) (addresses time-of-conviction approach under a similar recidivism statute)