United States v. St. Hill, 2014 U.S. App. LEXIS 18780

St. Hill pled guilty in 2012 to distributing oxycodone; district court looked to uncharged drug sales as relevant conduct for sentencing under § 1B1.3(a)(2).
PSR described a June 26, 2012 controlled buy: St. Hill sold 20 oxycodone pills for $600 to a confidential informant with a DEA agent present.
PSR also noted a January–May 2012 pattern where a CI purchased multiple 30 mg oxycodone pills; St. Hill allegedly sold oxycodone in April 2012 and earlier, contributing to substantial quantities.
Paragraph 4A of the PSR attributed additional 76.65 grams of oxycodone to St. Hill based on informants’ reports of large-scale trafficking and leadership of a group; controversy over reliability and relevance.
District court included paragraph 4A as relevant conduct, increasing base offense level and resulting Guidelines range from 30–37 months to 84–105 months; St. Hill received an 84-month sentence and appealed.
St. Hill argues the district court misapplied standards by (a) treating the conduct as part of a common scheme or plan or misapplying the same course of conduct standard, and (b) not tying uncharged conduct directly to the offense of conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court apply the wrong standard?	St. Hill argues the court treated 4A as common scheme/plan (or used an improper standard).	St. Hill contends the court relied on the wrong standard and method in linking 4A to the offense of conviction.	No reversible error; standard properly applied.
Was the method of comparison correct for same course of conduct?	St. Hill claims the court compared 4A to other relevant conduct, not directly to the offense of conviction.	St. Hill asserts improper transitive comparison; the court should tie uncharged conduct to the charged offense.	No plain error; the comparison and nexus were permissible and did not prejudice substantial rights.
Did any error affect the sentence enough to require reversal?	St. Hill contends the error could have yielded a lower sentence if analyzed differently.	St. Hill would not have a different sentence under the correct method; the original outcome remains.	No prejudicial impact; sentence affirmed.

United States v. Blanco, 888 F.2d 907 (1st Cir. 1989) (common scheme or plan; same course of conduct concepts are closely related)
United States v. Santos Batista, 239 F.3d 16 (1st Cir. 2001) (relevant conduct must be linked to the offense of conviction)
United States v. Buck, 324 F.3d 786 (5th Cir. 2003) (limitations on linking uncharged conduct to charged conduct)
United States v. Rhine, 583 F.3d 878 (5th Cir. 2009) (common factors for same scheme or plan; substantial connection criteria)
United States v. Cyr, 337 F.3d 96 (1st Cir. 2003) (relevance of uncharged conduct to charged offense; permissible linking guidance)
United States v. Pinnick, 47 F.3d 434 (D.C. Cir. 1995) (link must connect to offense of conviction, not merely other offenses)
United States v. Bullock, 454 F.3d 637 (7th Cir. 2006) (must show direct connection to offense of conviction, not via other conduct)
United States v. Dominguez Benitez, 542 U.S. 74 (U.S. 2004) (plain error standard and need for prejudice in sentencing)
United States v. Tavares, 705 F.3d 4 (1st Cir. 2013) (plain error standard for appellate review)
United States v. Gilman, 478 F.3d 440 (1st Cir. 2007) (prejudice required to reverse sentencing calculations)
United States v. Carrozza, 4 F.3d 70 (1st Cir. 1993) (predecessor considerations on relevant conduct and connections)