Sentencing; Career-offender guideline; USSG § 4B1.1; Controlled-substance offense; § 4B1.2(b); State-law convictions; Sentencing Commission authority; 28 USC § 994(h); Distinguishing United States v LaBonte; Loper Bright Enters v Raimondo; Downward variance; Procedural reasonableness; Substantive reasonableness; 18 USC § 3553(a)

The court held that the career-offender guideline validly includes state-law drug convictions and that defendant’s within-guidelines sentence was procedurally and substantively reasonable. Defendant pled guilty to a federal fentanyl offense, conceded he was “technically a career offender,” and sought a downward variance based partly on a policy disagreement with the career-offender guideline. On appeal, the court rejected his claim that the Sentencing Commission exceeded its authority by including state-law drug convictions. It reasoned that the phrase offenses “described in” federal drug statutes refers to conduct, not only convictions under those statutes, and “covers state-law offenses which map onto their federal counterparts.” The court also held that even if § 994(h) were read narrowly, it would set only a floor for required predicate offenses, “not a ceiling,” and the Commission could include state-law predicates under its general guideline authority. The court next rejected defendant’s procedural reasonableness challenge because the district court “exhaustively considered the § 3553(a) factors,” including his upbringing, brain development, criminal history, offense seriousness, fentanyl trafficking, deterrence, and public safety. Finally, the court held that the bottom-of-guidelines sentence was substantively reasonable, noting within-guidelines sentences receive a presumption of reasonableness and the court was not required to adopt defendant’s preferred view of Commission reports or proposed amendments. Affirmed.