Seventh Circuit - Relevant Conduct

United States v. Ford, 988 F.3d 970 (7th Cir. 2021). The six-level enhancement at §2B3.1(b)(2)(B) applied to a defendant whose codefendant “otherwise used” a firearm during an attempted robbery of a gas station. There was “ample evidence” that the defendant was in on his codefendant’s plan to rob the gas station “from the start and that he continued to help after [the codefendant] brandished the firearm.” These facts supported a reasonable inference that the use of the firearm was within the scope of the defendant’s “jointly undertaken criminal activity, in furtherance of it, and reasonably foreseeable,” as required by §1B1.3(a)(1)(B).

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