U.S. v. Briggs

Dist. Ct. erred in sentencing defendant to 84-month term of incarceration on felon in possession of firearm charge, where said sentence was based, in part, on imposition of 4-level enhancement under section 2K2.1(b)(6)(B) of USSG for possession of firearm in connection with felony possession of drugs. While search of defendant’s home revealed that defendant had firearms in same room as .49 grams of cocaine, Dist. Ct. never made any findings about how defendant’s felony possession of cocaine was connected to his firearms. Moreover, mere fact that guns and drugs were found near each other was insufficient, by itself, to establish nexus between them.