UNITED STATES OF AMERICA v. CEDRIC DOUGLAS CANZATER
July 20, 2026·25-4343·Per Curiam·Per Curiam·By James Taylor
The Fourth Circuit affirmed a drug trafficking sentence enhancement based on a prior conviction treated as a serious felony despite concurrent sentencing arguments.
Cedric Douglas Canzater pleaded guilty to possession with intent to distribute fentanyl and methamphetamine. The district court imposed a one hundred eighty month sentence and enhanced it based on a two thousand and eight drug conviction deemed a serious drug felony.
The court’s reasoning
The court held that concurrent sentences remain separate and distinct terms of imprisonment even when served simultaneously. Canzater served one day of each concurrent sentence and was released within fifteen years of the instant offense, satisfying the statutory requirement.
What it means going forward
Clarifies that concurrent sentences do not artificially extend release dates for recidivist enhancement purposes under federal drug statutes.
