United States v. Corey Brown and Gregory Hall, ___ F.3d ___, 07-13007 (November 10, 2009) (
Alarcon, Carnes, Faye)
[This is a capsule summary of one of the issues discussed in Brown. Other issues and deeper analysis to be found in our Blues Newsletter.] Two defendants were convicted at trial of various charges including drug conspiracy charges. The facts shown at trial established that the defendants were among several individuals who sold drugs at various
trees in a particular neighborhood, sort of like a
farmer's market for crack cocaine. Although defendants sold drugs at various assigned trees, and were frequently in competition with one another, the Eleventh Circuit upheld the conspiracy convictions on the basis that their cooperative efforts combined towards a common goal of keeping the market supplied with drugs. Also, a consistent series of transactions made the area attractive to purchasers which was to their common benefit. The opinion drew support from another case from last year,
United States v. Westry in which three drug dealers maintained adjacent crack houses which competed with one another at times.
[This is a capsule summary of one of the issues discussed in Brown. Other issues and deeper analysis to be found in our Blues Newsletter.] Two defendants were convicted at trial of various charges including drug conspiracy charges. The facts shown at trial established that the defendants were among several individuals who sold drugs at various trees in a particular neighborhood, sort of like a farmer's market for crack cocaine. Although defendants sold drugs at various assigned trees, and were frequently in competition with one another, the Eleventh Circuit upheld the conspiracy convictions on the basis that their cooperative efforts combined towards a common goal of keeping the market supplied with drugs. Also, a consistent series of transactions made the area attractive to purchasers which was to their common benefit. The opinion drew support from another case from last year, United States v. Westry in which three drug dealers maintained adjacent crack houses which competed with one another at times.
