Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Fifth Circuit: USA v. Alfredo Heard
Conviction for drug possession entered during the pendency of the drug conspiracy is not per se part of the same pattern of relevant conduct, but can be considered an element of criminal history.