Sixth Circuit - Firearms

United States v. Fugate, 964 F.3d 580 (6th Cir. 2020). It was impermissible double counting to apply enhancements in §2K2.1 (b)(5) and (b)(6)(B) to a defendant convicted of firearms trafficking, because each enhancement was based on the defendant’s trafficking of firearms. The court applied the §2K2.1(b)(6)(B) enhancement for knowingly trafficking stolen firearms and for selling the firearms to drug traffickers and gang members, as well as the §2K2.1(b)(5) enhancement for firearms trafficking.

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