claim without merit, but any error would be harmless because the mandatory life sentence is triggered by two or more felony drug convictions. This court has adopted a “separate criminal episodes” test for determining whether prior felony drug convictions are separate predicate convictions for purposes of enhancement under § 841(b)(1)(A). This test asks whether the convictions arise from “separate criminal episodes” that are “distinct in time.” “An episode is an incident that is part of a series, but forms a separate unit within the whole. Although related to the entire course of events, an episode is a punctuated occurrence with a limited duration.” United States v. Hughes, 924 F.2d 1354, 1361 (6th Cir.1991). Although the records indicate that the sen 36 (6th Cir.2006) (per curiam) (<HOLDING>). C. Constitutionality of Life Sentence
holding a sentence enhancement for two prior convictions must be based on separate criminal episodes holding that although sentencing for separate convictions arising from unrelated crimes can take place on same day sentences cannot be part of same sentencing proceeding those separate convictions in same proceeding cannot be considered sequential for purposes of habitualization holding that prior drug convictions that were four ten and eleven years old were not so remote from the charged drug offenses as to render them inadmissible holding separate convictions for drug transactions occurring four or five days apart were properly counted as separate convictions holding that only one offense should have been charged when four separate packages of the same drug were found