11th Circuit upholds 151-month sentence for Yaphet Martin, ruling the Sentencing Commission lawfully included state…
United States v. Yaphet Martin
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11th Circuit upholds 151-month sentence for Yaphet Martin, ruling the Sentencing Commission lawfully included state drug convictions in the career-offender enhancement definition.
Why it matters
The Eleventh Circuit affirmed Yaphet Martin's 151-month prison sentence, rejecting his argument that the U.S. Sentencing Commission exceeded its authority by including state drug offenses in the definition of 'controlled substance offense' used to trigger the career-offender sentencing enhancement. The court found that its own prior precedents, from cases called Weir and Pridgeon, directly controlled the outcome and required affirmance. Under those precedents, the Sentencing Commission had independent statutory authority under federal law to define controlled substance offenses more broadly than the specific federal statutes listed in one section of the authorizing law.
Who it affects
This ruling directly affects federal criminal defendants in the Eleventh Circuit (covering Florida, Georgia, and Alabama) who have prior state drug felony convictions and are being sentenced under the career-offender guideline, as those state convictions can continue to be used to increase their federal sentences.
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Decision issued Jul 13, 2026
Unpublished opinion
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Jul 13, 2026 · Unpublished opinion
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Yaphet Martin was sentenced to 151 months in federal prison and challenged that sentence on appeal. The core legal question was whether the U.S. Sentencing Commission went beyond the authority Congress gave it when it wrote a definition of 'controlled substance offense' that includes prior state drug convictions, not just prior federal drug convictions. Martin argued that Congress, in 28 U.S.C. Section 994(h), only directed the Commission to apply the career-offender enhancement based on specific federal drug statutes, so the Commission had no power to expand that list to cover state offenses. The Eleventh Circuit disagreed and affirmed the sentence. The court explained that it is bound by its own prior panel decisions unless they are overruled by the full court sitting en banc or by the Supreme Court. Two prior Eleventh Circuit cases, United States v. Weir and United States v. Pridgeon, had already addressed very similar arguments about whether the Commission exceeded its authority in defining 'controlled substance offense,' and both cases concluded the Commission had not overstepped. Those rulings controlled the outcome here. The court also addressed Martin's reliance on a Supreme Court case called LaBonte, which held that the Sentencing Commission must follow the plain text of Section 994(h). The Eleventh Circuit noted that Pridgeon was decided after LaBonte and still upheld the Commission's broader definition, meaning LaBonte did not undercut the binding precedents that governed this appeal. The court noted that Weir was partially overruled by a more recent en banc decision called Dupree, but only on the separate question of whether inchoate offenses like conspiracy count as controlled substance offenses. The Dupree decision did not address or disturb the reasoning about the Commission's general authority to include state offenses, so the parts of Weir relevant to Martin's case remained good law. The source text does not reflect any dissent from the three-judge panel. The ruling does not appear to change existing law but confirms that prior state drug felony convictions can count as predicate offenses for the federal career-offender sentencing enhancement in the Eleventh Circuit.
CITATION AND RECORD
Record source: CourtListener
USCA11 Case: 25-12305 Document: 34-1 Date Filed: 07/13/2026 Page: 1 of 6 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-12305 Non-Argument Calendar ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus YAPHET MARTIN, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 8:23-cr-00332-WFJ-LSG-1 ____________________ Before JORDAN, KIDD, and BLACK, Circuit Judges. PER CURIAM: Yaphet Martin appeals his 151-month imprisonment sen- tence, asserting the district court erred by applying the career-of- fender enhancement pursuant to U.S.S.G. § 4B1.1. He contends USCA11 Case: 25-12305 Document: 34-1 Date Filed: 07/13/2026 Page: 2 of 6 2 Opinion of the Court 25-12305 the Sentencing Commission exceeded its statutory authority under 28 U.S.C. § 994(a) by including state offenses within its definition of “controlled substance offense,” and thus his previous state drug conviction does not qualify as a predicate offense for purposes of the enhancement. After review, 1 we affirm. Congress has assigned the Sentencing Commission to prom- ulgate and distribute to the courts sentencing guidelines and gen- eral policy statements. 28 U.S.C. § 994(a). Congress has tasked the Sentencing Commission with ensuring “the guidelines specify a sentence to a term of imprisonment at or near the maximum term authorized for categories of defendants in which the defendant is eighteen years old or older and” has two prior felony convictions of either “a crime of violence” or “an offense described in section 401 of the Controlled Substances Act (21 U.S.C. 841), sections 1002(a), 1005, and 1009 of the Controlled Substances Import and Export Act (21 U.S.C. 952(a), 955, and 959), and chapter 705 of title 46.” 28 U.S.C. § 994(h). The Sentencing Guidelines provide that a defendant quali- fies as a career offender if: (1) he was at least 18 years old when committing the instant offense; (2) the instant felony offense is ei- ther a “crime of violence” or a “controlled substance offense”; and (3) he has at least 2 prior felony convictions for a crime of violence 1 We review de novo whether a prior conviction qualifies as a “controlled sub- stance offense” under the Sentencing Guidelines. United States v. Rowe, 143 F.4th 1318, 1324 (11th Cir. 2025). USCA11 Case: 25-12305 Document: 34-1 Date Filed: 07/13/2026 Page: 3 of 6 25-12305 Opinion of the Court 3 or controlled substance offense. U.S.S.G. § 4B1.1(a). A “controlled substance offense” is an offense under federal or state law, punishable by imprisonment for a term exceeding one year, that . . . prohibits the manufacture, import, export, distribution, or dispensing of a controlled sub- stance . . . or the possession of a controlled sub- stance . . . with intent to manufacture, import, ex- port, distribute, or dispense. Id. § 4B1.2(b). Martin contends that although § 4B1.2(b) includes state drug felonies, the definition conflicts with Congress’s specific directive in § 994(h). He cites United States v. LaBonte, 520 U.S. 751 (1997), for the proposition that the Sentencing Commission must follow the plain text of § 994(h) and cannot expand it by invoking the Commission’s general authority under § 994(a). In LaBonte, the Su- preme Court addressed the Sentencing Commission’s preclusion of consideration of any statutory sentence enhancements in the meaning of “maximum term authorized” from § 944(h). LaBonte, 520 U.S. at 754-55. The Court held that “maximum term of impris- onment authorized” meant the maximum prison term available for the offense of conviction including any statutory sentencing en- hancements because the plain language of § 994(h) controlled over any inconsistent interpretation by the Sentencing Commis- sion. Id. at 756-57, 762. Our decisions in United States v. Weir, 51 F.3d 1031, 1032 (11th Cir. 1995), overruled on other grounds by United States v. Dupree, USCA11 Case: 25-12305 Document: 34-1 Date Filed: 07/13/2026 Page: 4 of 6 4 Opinion of the Court 25-12305 57 F.4th 1269 (11th Cir. 2023) (en banc), and United States v. Pridg- eon, 853 F.3d 1192, 1199 (11th Cir. 2017), control this case. See United States v. White, 837 F.3d 1225, 1228 (11th Cir. 2016) (explain- ing we are bound to adhere to our prior panel precedent unless that precedent has been overruled by this Court sitting en banc or by the Supreme Court). In Weir, we addressed whether the Sentenc- ing “Commission overstepped its mandate when it classified drug conspiracies as controlled substance offenses” because § 994(h) “does not specifically refer to the conspiracy statute when delineating which statutes’ violation provide for the imposition of career offender status.” Weir, 51 F.3d at 1032. We held the Com- mission had not overstepped its authority, because (1) “§ 994(a) . . . provides independent grounds for the career offender provision, and the language of this section grants sufficient authority to the Commission to include drug conspiracies in its definition of con- trolled substance offenses”; (2) “the legislative history indicates that the specific offenses listed in [§] 994(h) are not necessarily exhaus- tive”; and (3) “common sense dictates that conspiring to distribute drugs constitutes a controlled substance offense.” Id. 2 2 In 2023, Weir was overruled in part by United States v. Dupree, 57 F.4th 1269 (11th Cir. 2023) (en banc). In Dupree, we held “the definition of ‘con- trolled substance offense’ in § 4B1.2(b) does not include inchoate offenses.” 57 F.4th at 1271. In so holding, we noted “the plain text of § 4B1.2(b) unam- biguously excludes inchoate crimes.” Id. at 1280. We did not address the scope of the Sentencing Commission’s authority to define “controlled sub- stance offense” under § 994(h). See generally id. USCA11 Case: 25-12305 Document: 34-1 Date Filed: 07/13/2026 Page: 5 of 6 25-12305 Opinion of the Court 5 In Pridgeon, decided after the Supreme Court’s LaBonte deci- sion, the appellant contended the Sentencing Commission had “ex- ceeded its statutory authority in promulgating § 4B1.2. . . . by treat- ing crimes without an element of mens rea as to the illicit nature of the controlled substance.” United States v. Pridgeon, 853 F.3d at 1199. Pridgeon asserted the Commission had “acted outside the express directives of 28 U.S.C. § 994(h).” Id. We held the Commis- sion
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