Relevant conduct is an important concept in the U.S. Sentencing Guidelines. According to the U.S. Court of Appeals for the 2nd Circuit, relevant conduct is "almost a term of art as a result of its detailed exposition in Sections 1B1.3 (Relevant Conduct), 4 (Criminal History); and 3D1.2(d) (Drug Trafficking)."[1] The U.S. Sentencing Commission notes, "Deemed the 'cornerstone' of the federal sentencing guidelines, relevant conduct defines the scope of behavior that must be considered in every federal case."[2]