In United States v. Gordillo, No. 18-12095 (Apr. 17, 2019) (Marcus, Black, Walker), the Court upheld the defendant's sentence against a guideline challenge.
Specifically, the defendant challenged his base offense level under 2K2.1 on the ground that his offense did not involve a semi-automatic firearm in "close proximity" to a high-capacity magazine. The Court concluded that a high-capacity magazine in a bag was in "close proximity" to a locked firearm in a case ten feet away in the same room. The Court interpreted "close proximity" to encompass both physical distance and accessibility. Here, ten feet was close physical proximity, and the Court rejected the defendant's argument that the firearm was inaccessible just because it was locked in a separate container.