United States v. Coleman, 854 F.3d 81

Coleman pleaded guilty to conspiracy to distribute and possess with intent to distribute cocaine base; charged under 21 U.S.C. §§ 841, 846; sentenced to 46 months (bottom of Guidelines range).
DEA investigation in 2014 produced intercepted calls, a confidential-source buys, and December 8, 2014 arrest at Coleman’s residence where drugs and paraphernalia were seized and a juvenile was present.
Coleman admitted during post-arrest statements that co-conspirator Tasheem Carter routinely "traded guns for drugs," that he witnessed a transaction where Carter received a handgun for drugs, and that he once awaited what he assumed would be a gun delivery by another co-defendant.
At sentencing the court applied a two‑level U.S.S.G. § 2D1.1(b)(1) enhancement for possession of a dangerous weapon, gave safety‑valve and acceptance‑of‑responsibility reductions, yielding offense level 23 and a Guidelines range of 46–57 months (Criminal History I).
Coleman appealed, arguing (1) the § 2D1.1(b)(1) enhancement was improper because no firearm was tied to the December 8 conspiracy date, and (2) his within‑Guidelines sentence was substantively unreasonable and should have been varied downward.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2D1.1(b)(1) two‑level weapon enhancement was proper	Government: enhancement may be applied based on relevant conduct beyond the charged date; Coleman knew/foreseeable that co‑conspirators possessed firearms	Coleman: conspiracy lasted one day (Dec. 8) and no evidence ties firearms to that day, so enhancement is improper	Held: Enhancement proper — court may consider all relevant conduct; Coleman’s admissions showed knowledge and foreseeability of co‑conspirator firearms, and defendant failed to show connection was clearly improbable
Whether the within‑Guidelines 46‑month sentence was substantively unreasonable	Government: sentence reasonable; district court considered § 3553(a) factors and defendant’s mitigation	Coleman: court should have given a variance for cooperation, difficult upbringing, and crack/powder disparity	Held: Substantively reasonable — district court considered § 3553(a) factors and gave a defensible sentence within the Guidelines; no abuse of discretion

United States v. Battle, 637 F.3d 44 (1st Cir. 2011) (reasonableness review framework)
Gall v. United States, 552 U.S. 38 (2007) (abuse‑of‑discretion standard for substantive reasonableness)
United States v. Clogston, 662 F.3d 588 (1st Cir. 2011) (procedural and substantive reasonableness analysis)
United States v. Trinidad‑Acosta, 773 F.3d 298 (1st Cir. 2014) (procedural‑reasonableness errors listed)
United States v. Burgos‑Figueroa, 778 F.3d 319 (1st Cir. 2015) (foreseeability of co‑conspirator firearm possession warrants enhancement)
United States v. Casas, 356 F.3d 104 (1st Cir. 2004) (knowledge and foreseeability of firearms in conspiracy context)
United States v. Corcimiglia, 967 F.2d 724 (1st Cir. 1992) (burden on government to establish nexus; defendant must show clear improbability)
United States v. Martin, 520 F.3d 87 (1st Cir. 2008) (sentencing as a judgment call)