Eighth Circuit - Firearms

United States v. Roberts, 958 F.3d 675 (8th Cir. 2020). Section 2K2.1(b)(6)’s four-level increase for possession of a firearm “in connection with” another felony offense applies when a defendant violates an Iowa law prohibiting the sealed carrying of a weapon. Section 3B1.4’s two-level adjustment for use of a minor does not apply when a defendant purchases a firearm from a minor.

United States v. Caudle, 968 F.3d 916 (8th Cir. 2020). The court did not clearly err in applying §2K2.1(b)(1)(A)’s two-level increase for multiple firearms when the challenged firearm was found in the defendant’s wife’s car, which was the only car possessed by the couple. The defendant had used his wife’s car; the challenged firearm was kept (on other occasions) in the couple’s home, to which the defendant had unrestricted access; and magazines and spent casings matching the challenged firearm were found in the home.

United States v. Nelson, 982 F.3d 1141 (8th Cir. 2020). USSG §5G1.3(d) applies to a defendant subject to an undischarged term of imprisonment for relevant and non-relevant conduct, and in such cases, a court may choose to run the sentence for the instant offense concurrently, partially concurrently, or consecutively to the undischarged term of imprisonment.

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