In United States v. Jackson, No. 19-14883 (May 18, 2021) (William Pryor, Luck, Ed Carnes), the Court affirmed the defendant’s sentence.
The sentence was enhanced under USSG 2K2.1(b)(6)(B) for using or possessing a gun “in connection with” another felony, which occurs where the gun facilitated, or had the potential to facilitate, the other felony offense. The district court did not clearly err by finding that connection here, where the defendant negotiated guns and drugs to be sold at the same time, even though the defendant ultimately sold the drugs first and the gun later. Coordinating the sale of both at the same time shored up the drug sale and allowed the seller to conduct two sales with a minimal increase in the risk of detection.
