United States v. Christopher Squire, 16-4862

Christopher Squire was convicted by jury of: aiding and abetting and possession with intent to distribute heroin (Count 1); possession with intent to distribute ≥100g heroin (Count 2); maintaining a place for drug use/distribution (Count 3); and possession of a firearm in furtherance of a drug trafficking crime (18 U.S.C. § 924(c), Count 4). Sentenced to 140 months’ imprisonment.
At trial a cooperating witness arranged to buy a large quantity of heroin from Squire’s codefendant, Brandon Anderson; Squire left his apartment, visited Anderson briefly, then drove Anderson to a Motel 6 where both were arrested.
Officers found ~9 grams of heroin on Anderson, $921 on Squire, and a blue Samsung flip phone in Squire’s truck. A search of Squire’s apartment uncovered ~300 grams of heroin in matching blue zipper bags, a large digital scale, three matching flip phones, and a loaded .357 revolver in plain view near >100 grams of heroin.
Squire admitted ownership of the firearm and the heroin in his apartment in a statement to police.
On appeal Squire challenged (1) sufficiency of evidence for Count 1 and Count 4, and (2) certain sentencing calculations: two criminal history points for juvenile convictions and collateral attack on the voluntariness of those prior pleas.

Issue	Squire's Argument	Government's Argument	Held
Sufficiency of evidence for aiding and abetting/possession with intent (Count 1)	Evidence insufficient to prove Squire participated in motel transaction or intended to distribute	Phone/meeting timeline, matching packaging, large quantity at apartment, scales, cash and burner phones support inference Squire participated and intended distribution	Affirmed – substantial evidence supports conviction
Sufficiency of evidence that firearm furthered drug trafficking (Count 4)	Firearm did not further the drug offense; no nexus shown	Gun was loaded, in plain view within arm’s reach of >100g heroin; firearms are tools of drug trade—jury could infer nexus	Affirmed – jury could reasonably find firearm furthered trafficking
Scoring two criminal history points for pre-18 state convictions	Points improper because offenses occurred before age 18	Sentencing Guideline §4A1.2(d)(2)(A) permits counting juvenile convictions where criteria met	Affirmed – juvenile convictions properly scored
Collateral attack on validity of prior state guilty pleas	Pleas involuntary because state court failed to advise full implications; convictions therefore infirm	Collateral attack barred unless prior conviction was reversed/vacated or obtained in violation of right to counsel	Affirmed – Squire may not collaterally attack prior convictions; no right-to-counsel claim

United States v. Zayyad, 741 F.3d 452 (4th Cir. 2014) (standard for reviewing sufficiency of evidence)
United States v. Gomez-Jimenez, 750 F.3d 370 (4th Cir. 2014) (jury’s role in drawing inferences from competing evidence)
United States v. Lomax, 293 F.3d 701 (4th Cir. 2002) (factors for determining whether firearm furthered drug trafficking)
United States v. Hall, 551 F.3d 257 (4th Cir. 2009) (elements of distribution offense)
Gall v. United States, 552 U.S. 38 (2007) (procedural reasonableness standard for sentencing review)
Custis v. United States, 511 U.S. 485 (1994) (limits on collateral attacks to prior convictions used to enhance federal sentences)