Yu Kikumura v. United States

How later courts describe this case

• waiving appellant’s argument where it merely referenced pleadings filed in the district court without stating facts or legal authority in support
• declining to rule on due process issues because even if the clear and convincing standard applied, the government met its burden of proof
• similar drug transaction eighteen months before the offense of conviction was relevant conduct because “both transactions were part of a regular pattern of drug distribution”