BAUER, Circuit Judge.
Gilbert Spiller was charged with two counts of distributing cocaine base, and one count of selling a firearm to a felon. He pleaded guilty. The government sought enhanced punishment under 21 U.S.C. § 851 due to Spiller's prior felony drug convictions. At sentencing, neither side objected to the calculated Guidelines range of 262 to 327 months. Spiller's counsel, however, argued for a below-Guidelines sentence, contending that the §...
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