United States v. Reyes-Torres, No. 18-2170 (1st Cir. 2020)
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The First Circuit affirmed Defendant's sentence of forty-two months' imprisonment for illegal possession of a machine gun, holding that the sentence was both procedurally and substantively reasonable.
On appeal, Defendant argued that the district court erroneously applied a four-level enhancement to his total offense level for possession of a firearm in connection with another felony of drug possession pursuant to U.S.S.G. 2K2.1(b)(6). Specifically, Defendant argued that possession of a firearm in connection with mere drug possession for personal use was insufficient to apply the enhancement. The First Circuit affirmed, holding (1) Defendant was clearly in possession of the firearm in furtherance of drug trafficking under this Court's case law, and therefore, the evidence was sufficient to justify an enhanced sentence for that reason; and (2) Defendant's sentence was substantively reasonable.
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