No. 21-5099October Term 2021Decided Jan 10, 2022
Guerrant v. United States
The key question is whether a broader state drug conviction can be used to trigger a tougher federal sentence under the career-offender guideline.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jan 10, 2022
- What it's about
This case asks whether a prior state drug conviction can be used to increase a federal sentence under the Sentencing Guidelines' career-offender rule when the state law covers substances that are not controlled under federal law. Guerrant is challenging the use of such a state distribution conviction as a qualifying predicate offense.
Question presented
Does a state conviction for distribution of a substance not defined as a "controlled substance" by federal law qualify as a career offender predicate conviction under the Sentencing Guidelines?
- Case path
United States Court of Appeals for the Fourth Circuit / Decision released Jan 10, 2022
- Area
Criminal Procedure
Briefing
What it's about
Guerrant is asking the Supreme Court to decide whether a state drug distribution conviction counts under the federal Sentencing Guidelines' career-offender rule when the state law covers substances that federal law does not. The case comes from the Fourth Circuit.
Vote
The case is pending, and oral argument has not been scheduled. Guerrant argues that a state distribution conviction should not count if the state law reaches substances not defined as controlled substances under federal law.
Impact
The answer could affect how long some federal defendants spend in prison. For example, a person with an earlier state drug conviction could face a higher federal sentencing range if that conviction is treated as a career-offender predicate.
What's next
The next thing to watch is a scheduling move from the Court, including whether oral argument is set. No decision window is available yet.
What is the core dispute in Guerrant v. United States?
The case asks whether a state drug distribution conviction counts under the federal career-offender guideline when the state law covers substances federal law does not.
Why could this case matter for federal defendants?
It could change sentencing ranges in federal court. Defendants with past state drug convictions may face longer or shorter recommended sentences depending on the answer.
What is the next procedural step to watch?
Watch for another scheduling move from the Supreme Court, including whether oral argument is set. No decision timing is available yet.
Decision
What the Court decided
The key question is whether a broader state drug conviction can be used to trigger a tougher federal sentence under the career-offender guideline.
Impact
The answer could affect how long some federal defendants spend in prison. For example, a person with an earlier state drug conviction could face a higher federal sentencing range if that conviction is treated as a career-offender predicate.
Not official Court text.
Opinion documents
Timing
Decided January 10, 2022
The Court released its decision on January 10, 2022 without hearing oral argument.
Documents
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 2, 2026
- Method
- Methodology