Eleventh Circuit - Firearms

United States v. Martinez, 964 F.3d 1329 (11th Cir. 2020). The enhancement at §2K2.2(b)(6)(B) for possession of a firearm in connection with another felony offense applied where the weapon was found in the defendant’s car near drug paraphernalia and the government proved that the defendant planned to trade the weapon for drugs.

United States v. Wilson, 979 F.3d 889 (11th Cir. 2020). A base offense level of 20 under §2K2.1(a)(4)(B) was appropriate where the defendant, an “unlawful user” of drugs, possessed a sawed-off shotgun. A defendant is an “unlawful user” so long as his use is “ongoing and contemporaneous with the commission of the offense.”

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