Seventh Circuit - Firearms

United States v. Ramirez, 983 F.3d 959 (7th Cir. 2020). In a felon-in-possession case, an upward variance from a range of 46-57 months to a sentence of 72 months was procedurally and substantively reasonable. The Commission’s recidivism statistics belied the defendant’s aging-out-of-crime argument, and the Guidelines did not adequately capture the risk posed by the defendant’s flight from arrest or the seriousness of his criminal history.

United States v. Slone, 990 F.3d 568 (7th Cir. 2021). The four-level enhancement at §2K2.1(b)(6)(B) for possessing a firearm “in connection with” drug trafficking applied to the defendant even though he had been acquitted on a state charge of drug possession with intent to distribute. The finding was supported by a preponderance of the evidence.

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