United States v. Chris Snuggs, 21-4011

Appellant Chris Carlton Snuggs pleaded guilty to being a felon in possession of a firearm (18 U.S.C. §§ 922(g)(1), 924(a)(2)) and received a 33‑month sentence.
The district court imposed a 4‑level Sentencing Guidelines enhancement under USSG § 2K2.1(b)(6)(B) for possessing a firearm "in connection with another felony offense."
The court identified the "other felony" as a North Carolina assault with a deadly weapon inflicting serious injury, based on Snuggs shooting his brother in the leg with a .22 pistol.
The sole disputed factual/legal point on appeal was whether the victim’s wound qualified as a "serious injury" under North Carolina law.
The district court found pain, blood loss, hospital treatment (including x‑ray showing metallic fragments), medication, and surgical follow‑up sufficient to support a serious‑injury finding; the Fourth Circuit reviewed the facts for clear error and law de novo.
The Fourth Circuit affirmed both the Guidelines enhancement and the substantive reasonableness of the 33‑month sentence (the court also noted the district court granted a downward variance and thoroughly considered § 3553(a) factors).

Issue	Snuggs' Argument	Government's Argument	Held
Whether USSG § 2K2.1(b)(6)(B) enhancement applies ("serious injury" under NC law)	The gunshot wound to the leg did not amount to a "serious injury" so the 4‑level enhancement was improper	The victim’s pain, blood loss, hospital treatment, x‑ray fragments, medications, and referral support a reasonable finding of serious injury	Affirmed — district court did not clearly err; evidence sufficed for the enhancement
Whether the 33‑month sentence is substantively unreasonable under 18 U.S.C. § 3553(a)	Sought probation; argued mitigating factors and rehabilitation made incarceration unnecessary	District court’s downward variance and chosen term reasonably balanced mitigating factors against offense seriousness, history of substance abuse, repeated family victimization, and lack of deterrence	Affirmed — below‑Guidelines sentence presumed reasonable; Snuggs failed to rebut that presumption

Gall v. United States, 552 U.S. 38 (U.S. 2007) (reasonableness standard for sentencing review)
United States v. Nance, 957 F.3d 204 (4th Cir. 2020) (procedural/substantive reasonableness framework)
United States v. Blount, 337 F.3d 404 (4th Cir. 2003) (government’s burden to prove Guidelines enhancement)
United States v. Cox, 744 F.3d 305 (4th Cir. 2014) (preponderance standard for sentencing factfinding)
United States v. Manigan, 592 F.3d 621 (4th Cir. 2010) (definition of preponderance standard)
State v. Morgan, 595 S.E.2d 804 (N.C. Ct. App. 2004) (factors for evaluating "serious injury")
State v. Walker, 694 S.E.2d 484 (N.C. Ct. App. 2010) (defining serious injury as physical/bodily injury and juror factfinding role)