US v. Strickland (Sentencing)
In US v. Strickland, No. 09-1527, police's search of defendant revealed a firearm and methamphetamine. Defendant was charged with, and pled guilty to, being a felon in possession of a firearm. The district court enhanced defendant's sentence under the Sentencing Guidelines on the ground that he possessed the firearm in connection with the commission of felony drug possession. According to the court's opinion, "[w]hile [the defendant] was being fingerprinted at the jail, a loaded Ruger .22 caliber revolver fell from [his] pants." Defendant "told the officer that he carried the gun because he was afraid of being robbed."
Defendant appealed but the Eighth Circuit affirmed the sentence, holding that the district court made the findings necessary to support the enhancement, because the district court affirmatively made a finding that the gun found on defendant's person facilitated or had the potential to facilitate his drug-possession offense.