district court erroneously held that a fact that triggers a mandatory minimum sentence must be proved beyond a reasonable doubt.

U.S. v. Malouf, No. 05-2245 (1st Cir. October 13, 2006)

Sentence for drug charges is reversed where the district court erroneously held that a fact that triggers a mandatory minimum sentence must be proved beyond a reasonable doubt. http://laws.lp.findlaw.com/1st/052245.html

U.S. v. Avila, No. 05-1894 (7th Cir. October 13, 2006)Sentence for possession of marijuana with intent to distribute is reversed and remanded where the sentencing judge erroneously held that events described in the presentencing report were part of the same course of conduct, common scheme or plan as the offense of conviction. http://caselaw.lp.findlaw.com/data2/circs/7th/051894p.pdf