Multiple Drug Sales Were Committed on Different Occasions; ACCA Sentence Affirmed

US v. Delossantos, 2012 WL 1948645 (Tenth Cir. May 30, 2012), published. Defendant pled guilty to felon in possession of a firearm. The only issue was whether he was an armed career criminal based on three or more prior convictions for a serious drug offense committed on occasions different from one another. There was no question he had four prior drug trafficking convictions. He argued they were not committed on occasions different from one another but were rather part of a single criminal episode. The court affirms that multiple drug sales qualify as separate offenses even if they are part of a sting operation orchestrated by the government.