United States v. Donald Cantrell, 714 F. App'x 217

Donald Ray Cantrell pleaded guilty to Count Three: possession of methamphetamine with intent to distribute, and received a within-Guidelines 70-month sentence.
The indictment arose from multiple events between March 11, 2015 and March 10, 2016, including controlled buys and recoveries of methamphetamine and cash.
On December 27, 2015 (in the Southern District), officers found Cantrell with ~$5,000, ~3.08 g suspected marijuana, four firearms (two handguns), ammunition, and other items; Cantrell does not dispute constructive possession of the weapons.
The district court applied a two-level U.S.S.G. § 2D1.1(b)(1) enhancement for possession of a firearm based on the December 27, 2015 conduct, even though that conduct was uncharged and occurred in a different district.
Cantrell objected, arguing the firearms were not connected to the offense of conviction; the court overruled the objection and Cantrell appealed.

Issue	Cantrell's Argument	Government's Argument	Held
Whether a two-level § 2D1.1(b)(1) firearm enhancement applies	Firearms found on Dec. 27, 2015 were not connected to the Count Three offense	Firearms were possessed in connection with drug activity from the same course of conduct; constructive possession and presence of cash/drugs link them	Enhancement affirmed: district court did not clearly err

United States v. Manigan, 592 F.3d 621 (4th Cir. 2010) (Government may rely on circumstantial evidence and constructive possession to show firearm connected to drug activity)
United States v. Mondragon, 860 F.3d 227 (4th Cir. 2017) (defendant must show connection between weapon and drug offense is “clearly improbable” to avoid enhancement)