In the case of Paul L. Glover v. United States, 2000, the U.S Supreme Court dealt with issues related to sentencing guidelines for drug offenses and whether a defendant's prior conviction should be considered in determining his sentence. The court upheld that under federal law, a judge can consider previous convictions when deciding on a sentence for current charges even if those past crimes were not presented during trial or admitted by the defendant. In this case, Glover had been convicted of possession with intent to distribute cocaine base and was sentenced based on two prior felony drug convictions which he did not admit nor were proven at trial. He appealed arguing that his due process rights were violated because he didn't have an opportunity to contest these earlier convictions before they influenced his new sentence.

In the dissenting opinion for Paul L. Glover v. United States, Justice Stevens argued that the majority's interpretation of 18 U.S.C §924(c) was incorrect and inconsistent with its legislative history. He contended that Congress intended to punish only those who actively employed a firearm during or in relation to a crime of violence or drug trafficking offense, not merely those who possessed one at the time of their arrest on unrelated charges. The language "uses...a firearm" should be interpreted as requiring active employment rather than mere possession according to him. Furthermore, he criticized the majority's reliance on Bailey v United States (1995), arguing it did not support such an expansive reading of §924(c). In his view, this decision would lead to disproportionately severe penalties for defendants whose conduct fell far short of what Congress sought to deter and punish through this statute.