United States v. Quincy Campbell, 37 F.4th 1345

Defendant Quincy Campbell pled guilty to four federal counts of distributing controlled substances (sales of crack and heroin) after his July 2017 arrest.
Campbell's criminal history included a 1998 aggravated-battery conviction (released Nov. 2001), a 2006 drug conviction later vacated, and a 2013 drug conviction.
Probation’s early PSRs treated Campbell as a career offender (2006 and 2013 convictions as predicates); after the 2006 conviction was vacated a fourth PSR removed the career-offender designation.
The government presented testimony from Emily McGrath that she bought drugs from Campbell beginning in summer 2016 and later made deliveries for him in 2017; the district court credited that testimony and counted the 2016 sales as relevant conduct.
Counting the 2016 conduct brought Campbell’s 1998 conviction within the 15-year lookback for U.S.S.G. § 4B1.1 predicates, changing his guideline range from 21–27 months (non-career-offender) to 188–235 months (career-offender).
The district court sentenced Campbell to 120 months (concurrent terms), expressly relied on the § 3553(a) factors, said it would impose the same sentence even if its relevant-conduct findings were wrong, and the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in treating Campbell’s summer 2016 sales as relevant conduct for Guideline calculations	Gov’t: McGrath’s testimony showed a continuous, regular course of drug sales from July 2016 through 2017 that properly counts as relevant conduct	Campbell: 2016 transactions were distinct (she was a customer then, not a courier) and McGrath’s testimony was unreliable	Court: District court’s credibility finding for McGrath was not clearly erroneous; relevant-conduct finding upheld and career-offender status lawful
Whether the 120-month sentence was substantively unreasonable	Gov’t: Judge reasonably exercised discretion, considered § 3553(a), and imposed a below-Guidelines sentence	Campbell: Sentence was greater than necessary given the non-career-offender range and circumstances	Court: Sentence was substantively reasonable; judge reasonably weighed § 3553(a) factors and avoided unwarranted disparity; affirmed

United States v. Tankson, 836 F.3d 873 (7th Cir. 2016) (explaining relevant-conduct/common-scheme-or-plan analysis)
United States v. Tate, 822 F.3d 370 (7th Cir. 2016) (deference to district court credibility findings at sentencing)
United States v. Etchin, 614 F.3d 726 (7th Cir. 2010) (guideline range based on false evidence can be clear error)
United States v. Farmer, 543 F.3d 363 (7th Cir. 2008) (factors for determining same course of conduct: similarity, regularity, temporal proximity)
United States v. White, 519 F.3d 342 (7th Cir. 2008) (upholding relevant-conduct findings for prolonged, consistent trafficking)
Gall v. United States, 552 U.S. 38 (2007) (district courts must consider § 3553(a) factors and may not presume Guidelines reasonable)
United States v. Booker, 543 U.S. 220 (2005) (advisory Guidelines framework)
United States v. Purham, 795 F.3d 761 (7th Cir. 2015) (below-Guidelines sentences presumed reasonable on appeal)
United States v. Marks, 864 F.3d 575 (7th Cir. 2017) (questioning arbitrary results from close Guideline distinctions)