the information was filed whether he affirms or denies that he has been previously convicted.”). Accordingly, he contends that the Government failed to meet its burden of proving the convictions. See United States v. Reliant, 568 F.3d 125, 141 (4th Cir.2009) (listing facts the government must prove). The district court’s error was, however, harmless. “Although § 851 [ (c) ] allows a defendant to attack a prior conviction ... [§ 851(e) ] precludes challenges to convictions ‘which occurred more than five years before the date of the information alleging such prior conviction.’ ” Rounsavall, 115 F.3d at 566, quoting 21 U.S.C. § 851(e); United States v. Samuels, 543 F.3d 1013, 1020 (8th Cir. 2008); see also Custis v. United States, 511 U.S. 485, 487, 114 S.Ct. 1732, 128 L.Ed.2d 517 (1994) (<HOLDING>). Henderson’s convictions occurred 20 and 16
holding that due to statute defendant cannot collaterally attack prior convictions used to enhance sentence unless in violation of the right to counsel holding that prior felony drug convictions that fall within the conspiracy period may be used to enhance the defendants sentence if the conspiracy continued after his earlier convictions were final holding amended language gives district courts discretion to permit collateral attack on prior convictions used to enhance sentence holding that a defendant cannot collaterally challenge a prior conviction used to calculate criminal history points holding that a defendant cannot collaterally attack a prior state conviction during a federal sentencing proceeding in a different case