The following excerpt is from U.S. v. Sterling, 742 F.2d 521 (9th Cir. 1984):
Sterling challenges only the sufficiency of the evidence to support the second of the five elements--the continuing series of violations requirement. This circuit has interpreted a "continuing series" as consisting of three or more federal narcotics violations. United States v. Valenzuela, 596 F.2d 1361, 1367 (9th Cir.), cert. denied, 444 U.S. 865, 100 S.Ct. 136, 62 L.Ed.2d 88 (1979).
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