Salinas v. United States

PETITIONER: Jeffrey Jerome Salinas
RESPONDENT: United States
LOCATION: United States Court of Appeals for the Fifth Circuit

DOCKET NO.: 05-8400
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 547 US 188 (2006)
DECIDED: Apr 24, 2006

Facts of the case

Jeffrey Jerome Salinas was charged with bank robbery in federal district court. The district court treated Salinas’ two prior robbery convictions as unrelated. But because he had a prior conviction for possession of a controlled substance, he was treated as a career offender for sentencing purposes, which meant that his sentence was increased in accordance with the U.S. Sentencing Guidelines. The U.S. Court of Appeals for the Fifth Circuit affirmed the district court’s ruling and held that the district court properly treated Salinas’ prior robbery convictions as unrelated and that his conviction for simple possession of a controlled substance was a “controlled substance offense” within the meaning of "career offender" for sentencing purposes.

Question

Is a prior conviction of simple possession of a controlled substance a “controlled substance offense” for sentencing purposes?