CRIMINAL LAW & PROCEDURE, SENTENCING
US v. McGowan, No. 06-1546 (7th Cir. February 28, 2007)
Sentence for distributing cocaine is vacated and remanded to the district court where the government did not meet its burden of proving that relevant conduct used to enhance defendant's sentence was part of the same course of action or common scheme or plan that gave rise to the defendant's conviction.
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