Buffin v. United States

Issue: (1) Whether the Sixth Circuit, in addressing an issue that has deeply divided the federal courts of appeals following this Court’s decision in United States v. Santos erred in defining “proceeds” in 18 U.S.C. § 1956(a)(1) as profits for purposes of Section 1956(a)(1)(A)(i), but “receipts” in the context of Section 1956(a)(1)(B)(i); and (2) whether the Sixth Circuit erred not only in applying the concurrent-sentence doctrine, in conflict with the Ninth Circuit’s conclusion that the doctrine is invalid, but also in creating a new divide in the circuits by concluding the doctrine applies even to convictions the government concedes are invalid.