Carter: Two Prior Drug Offenses Were Committed Separately Because Only One Received Location-Based Enhancement

 In United States v. Carter, No. 18-14806 (Aug. 12, 2020) (Grant, William Pryor, Antoon), the Court upheld the defendant’s ACCA sentence.

 The issue was whether two prior Alabama drug offenses were committed on separate occasions.  Based on a review of the indictment and plea admissions, the Court held that they were more likely than not committed separately, because only one of the two offenses received a location-based enhancement under state law.