U.S. v. Clinton

Dist. Ct. erred in sentencing defendant to 76-month term of incarceration on unlawful possession of firearm charge, where said sentence was based in part on 4-level enhancement under section 2K2.1(b)(6)(B) of USSG that required showing that defendant’s possession of firearm was in connection with another felony, which govt. argued was drug distribution offense that defendant had originally been charged with in addition to instant firearm charge. While record showed that police found instant firearm in defendant’s home, along with drugs, record did not support Dist. Ct. finding that said firearm facilitated defendant’s drug distribution activities, where: (1) record failed to show that defendant had purchased said firearm with drugs; and (2) Dist. Ct. failed to make any finding that firearm was in close proximity to area where drugs were found in defendant’s home or that significant amount of drugs were sold from defendant’s home so as to support finding that firearm facilitated defendant's drug distribution operations.