The U.S. Court of Appeals for the Ninth Circuit has affirmed a federal drug-trafficking sentence in United States v. Tekola, holding that a district court properly applied a sentencing enhancement for maintaining a premises used for drug distribution.
In a decision filed March 9, 2026, the court concluded that the defendant’s apartment functioned as the central hub of his drug-trafficking operation, supporting the enhancement under U.S.S.G. § 2D1.1(b)(12).
The ruling confirms that the enhancement may apply even when the premises used for drug trafficking also serves as the defendant’s residence.
The dispute in brief
The case arose after federal investigators traced fentanyl that killed a young person in Goleta, California, to Isaac Tekola. According to the opinion, agents determined through interviews and online message records that Tekola had been selling drugs for years and frequently used his apartment as the base for those activities.
A search warrant executed at the apartment uncovered multiple indicators of drug trafficking. Agents recovered nearly $13,000 in cash, phones, scales with residue, baggies, a pay-owe sheet and a vacuum sealer used for packaging drugs.
Authorities also discovered significant quantities of controlled substances in the residence, including cocaine, pills containing fentanyl and counterfeit pills containing methamphetamine. Tekola later admitted that the seized cash came from drug dealing and that a safe in his bedroom closet was used to store drugs and drug proceeds.
Messages recovered from Tekola’s phone further indicated that he conducted drug transactions from the apartment and used it as a central location for his distribution activity.
A federal grand jury subsequently indicted Tekola on multiple counts of possession with intent to distribute controlled substances under 21 U.S.C. § 841. Tekola pleaded guilty to the charges without entering into a plea agreement.
At sentencing, the district court applied a two-level enhancement under U.S.S.G. § 2D1.1(b)(12), concluding that Tekola had maintained the apartment for the purpose of distributing controlled substances. The court ultimately imposed a sentence of 105 months’ imprisonment.
What the court decided
On appeal, Tekola challenged the district court’s application of a sentencing enhancement under U.S.S.G. § 2D1.1(b)(12). He argued that although he sold drugs from the apartment, the property’s primary purpose was as his residence.
The Ninth Circuit rejected that argument and held that the district court did not abuse its discretion in applying the enhancement.
According to the panel, the record contained substantial evidence that Tekola used the apartment as the central hub of his drug-trafficking operation, supporting the conclusion that drug distribution was one of the premises’ primary uses.
The court therefore affirmed the district court’s judgment and Tekola’s 105-month sentence.
How the court got there
The court began by examining the relevant sentencing guideline. U.S.S.G. § 2D1.1(b)(12) increases a defendant’s offense level if the defendant maintained a premises for the purpose of manufacturing or distributing a controlled substance.
The guideline commentary clarifies that drug distribution does not have to be the sole purpose of the premises. Instead, the activity must be one of the defendant’s “primary or principal uses” of the property rather than merely an incidental use.
Tekola argued that the enhancement should not apply because the apartment primarily served as his residence. In his view, the guideline was intended to target stash houses or locations used mainly for drug distribution.
The Ninth Circuit rejected that interpretation, explaining that courts have repeatedly upheld the enhancement where defendants used their homes for substantial drug trafficking activity.
Turning to the record, the panel identified extensive evidence supporting the district court’s conclusion. Investigators recovered cash, drugs and equipment associated with narcotics distribution from the apartment, including scales, packaging materials and other tools of the trade.
Tekola admitted that the cash seized from the residence came from drug sales and that a safe in his bedroom was used to store drugs and drug proceeds.
Messages recovered from Tekola’s phone also demonstrated that the apartment served as a central location for his trafficking activity. The court found that the residence was where he stored narcotics, packaged drugs and coordinated transactions with customers.
Although Tekola also conducted drug deals in other locations, the panel concluded that the apartment functioned as the operational hub of his drug-trafficking activity.
Given this evidence, the Ninth Circuit held that the district court acted within its discretion in determining that drug distribution was one of the primary uses of the premises and in applying the sentencing enhancement.
Key takeaways for business
• Federal sentencing enhancements for drug-trafficking premises can apply even when the property is also the defendant’s primary residence.
• Courts assess whether drug distribution is a “primary or principal use” of the premises rather than the sole purpose of the property.
• Evidence such as drug-packaging equipment, large quantities of narcotics, cash proceeds and communications with customers can support a finding that a residence was used for distribution.
• A home used as the operational centre of a trafficking operation may qualify as a drug-distribution premises under the federal sentencing guidelines.
• Courts give significant deference to district court findings when reviewing sentencing guideline applications on appeal.
What happens next
The Ninth Circuit affirmed the district court’s judgment, leaving Tekola’s 105-month sentence in place.
The opinion does not indicate any further procedural steps.
Case details
Court: U.S. Court of Appeals for the Ninth Circuit
Date: March 9, 2026
Case name: United States v. Tekola
Docket number: 24-5467
Area of law: Criminal appeal / federal sentencing
Result: District court judgment affirmed