The sixteen-level enhancement under U.S.S.G. §2L1.2(b)(1)(A)(i) for a "drug trafficking offense" includes both completed and inchoate offenses, even conspiracies without overt acts

 In United States v. Garcia-Vasquez, Appeal No. 22-2219, the Third Circuit held that the sixteen-level enhancement under U.S.S.G. § 2L1.2(b)(1)(A)(i) (2015) applies to anyone with a prior conviction for a “drug trafficking offense.” The enhancement’s text captures a wide swath of “offense[s],” both completed and inchoate, and even conspiracies without overt acts. Therefore, the Court held it need not consider the Guideline’s commentary or the rule of lenity and affirmed the district court's application of the enhancement.