171723P.pdf   07/13/2018  United States  v.  James Watson, Jr.
   U.S. Court of Appeals Case No:  17-1723
   U.S. District Court for the Eastern District of Arkansas - Little Rock   
   [PUBLISHED] [Kelly, Author, with Loken and Gruender, Circuit Judges] 
   Criminal case - Criminal law and sentencing. Claims the court erred in 
   admitting prior bad acts evidence and evidence regarding a controlled buy 
   of drugs rejected; the evidence did not vary from the indictment; evidence 
   was sufficient to support defendant's conviction for drug distribution; 
   any error in failing to require the government to prove certain prior 
   offenses for sentencing purposes was harmless; no error in assessing three 
   criminal points for a theft and, in any event, the matter did not affect 
   the calculation of defendant's criminal history score; the district court 
   did not abuse its discretion in varying upwards based on defendant's 
   extensive and violent criminal history, as well as the need to protect the 
   community and keep defendant confined until he aged out of criminality.