Diaz

Jesse Vasquez was a mid-level leader in the Florencia Trece gang who was convicted of drug-related -crimes for his part in the gang’s drug trafficking operations. The district court sentenced Vasquez to life imprisonment because his two prior California felonies qualified him for a mandatory sentence ■ enhancement under 21 U.S.C. § 841 .

Four years after Vasquez’s sentencing, California adopted Proposition 47, which allowed California courts to reclassify certain felony convictions as misdemeanor convictions, Vasquez successfully petitioned a California court to reclassify ones of his prior: California felonies- — on which his federal enhancement was based — as a misdemeanor. Vasquez" now argues that his federal enhancement should be invalidated because he no longer stands convicted of two. prior felonies as §, 841 requires.

We have previously held that a state granting post-conviction relief from a state conviction cannot undermine a federal sentence enhancement based on that conviction. We have upheld this rule even where a state dismisses or expunges the underlying state conviction the. federal enhancement is. based on. We.see no reason to treat a change to the…