The following excerpt is from U.S. v. Wong, 2 F.3d 927 (9th Cir. 1993):
4 Statutory maximum sentences may curtail the effect of some enhancements for relevant conduct, but their limiting effect is increasingly small, particularly in drug cases. For example, 15 years ago the maximum penalty for possession with the intent to distribute cocaine, no matter the quantity, was 15 years in prison, and the prisoner was eligible for parole after serving just five years. 21 U.S.C. Sec. 841(b)(1)(A) (1982 ed.). Today, a person with no criminal record who is convicted of possession with intent to distribute 5 kilograms of cocaine (or 50 grams of crack) faces a maximum term of life without parole. 21 U.S.C. Sec. 841(b)(1)(A). (West Supp.1993). See United States v. Jewel, 947 F.2d 224, 240 (7th Cir.1991) (Easterbrook, J., concurring) (discussing increasing statutory maximums for drug offenses).
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