99 F.4th 407
7th Cir.2024Background
- Randy Shane Craft pleaded guilty in 2019 to conspiracy to distribute over 50 grams of methamphetamine, in violation of 21 U.S.C. §§ 846 and 841.
- Craft supplied methamphetamine from Texas to Frank Shaffer, who transported it to Illinois for sale; others assisted Shaffer after his parole.
- Some drug handoffs from Craft to Shaffer happened at Craft’s house, but most occurred at a nearby gas station; Craft used drug proceeds to pay household expenses.
- At sentencing, the district court applied two enhancements: maintaining a premises for drug distribution and a managerial/supervisory role in the conspiracy.
- The court sentenced Craft to 150 months (below the guideline range); Craft appealed the application of both enhancements.
Issues
| Issue | Government's Argument | Craft's Argument | Held |
|---|---|---|---|
| Premises enhancement under U.S.S.G. § 2D1.1(b)(12) | Craft’s home was used to hand off and store drugs; proceeds paid rent/utilities | Distribution from home was infrequent/incidental; most sales elsewhere | Enhancement did not apply; error to impose |
| Role enhancement under U.S.S.G. § 3B1.1 | Craft managed proceeds, enlisted others, and led aspects of conspiracy | Only sourced drugs; didn’t direct others’ distribution | Enhancement upheld; sufficient evidence |
Key Cases Cited
- United States v. Flores-Olague, 717 F.3d 526 (7th Cir. 2013) (frequent storage and sales from home warrant premises enhancement)
- United States v. Contreras, 874 F.3d 280 (7th Cir. 2017) (premises enhancement applies when home is used for drug deals on multiple occasions with other supporting facts)
- United States v. Sanchez, 710 F.3d 724 (7th Cir. 2013) (livelihood from drug sales is relevant but not determinative for premises enhancement)
- United States v. Winfield, 846 F.3d 241 (7th Cir. 2017) (drug proceeds as livelihood and frequent sales/storage at home support enhancement)
- United States v. Grigsby, 692 F.3d 778 (7th Cir. 2012) (role enhancement applies for managing conspiracy proceeds)
- United States v. House, 883 F.3d 720 (7th Cir. 2018) (management/supervision defined for role enhancement)