173341P.pdf   11/19/2018  United States  v.  Anthony Harris
   U.S. Court of Appeals Case No:  17-3341
   U.S. District Court for the Southern District of Iowa - Davenport   
   [PUBLISHED] [Loken, Author, with Benton and Shepherd, Circuit Judges] 
   Criminal Case - sentencing. Because the government failed to prove a 
   meaningful relationship between discreet transactions of different drugs 
   and there was no direct evidence Harris distributed cocaine base, the 
   district court clearly erred in including as part of the relevant drug 
   quantity 17.5 grams of cocaine base, thus reducing the base offense level 
   to 22. In addition, the district court plainly erred in assigning a 
   criminal history point to a juvenile sentence imposed more than five years 
   before the commencement of the instant offense. The error placed Harris in 
   a wrong criminal history category and affected his substantial rights 
   because the district court did not expressly state that it would have 
   imposed the same sentence even if a lower guidelines range applied. 
   Accordingly, the sentence is vacated and remanded for resentencing.