United States v. Donovan Johnson, 2017 U.S. App. LEXIS 2078

Donovan K. Johnson pled guilty to being a felon in possession of a firearm under 18 U.S.C. §§ 922(g)(1) and 924(a)(2).
Officers observed Johnson exit a house with a firearm partially visible, then enter a vehicle; the vehicle was stopped for a traffic violation.
During the stop officers saw Johnson reaching under his seat; a search recovered a firearm in the car and 72 heroin capsules on Johnson.
The district court applied a 4-level enhancement under U.S.S.G. § 2K2.1(b)(6)(B) for possessing a firearm "in connection with" another felony (drug offense) and sentenced Johnson to 72 months.
Johnson appealed, arguing the heroin was a user amount (not distribution) and that the firearm was not possessed "in connection with" another felony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the § 2K2.1(b)(6)(B) 4‑level enhancement applies because the firearm was possessed "in connection with" another felony	Johnson: gun was not used to facilitate a separate felony; court relied on proximity only	Government: gun facilitated or had potential to facilitate drug distribution given location and quantity	Court: Affirmed—district court found firearm facilitated or had potential to facilitate distribution; enhancement proper
Whether the heroin quantity was a distribution amount rather than a user amount	Johnson: 72 capsules were only a user amount, so trafficking inference improper	Government: quantity and context supported distribution inference	Court: Did not address after finding firearm facilitated drug possession; enhancement upheld without resolving quantity issue

United States v. Blankenship, 552 F.3d 703 (8th Cir.) (distinguishes application when underlying drug offense is trafficking vs. possession)
United States v. Fuentes Torres, 529 F.3d 825 (8th Cir.) (possession-based drug offenses require a finding that the firearm facilitated the offense)
United States v. Holm, 745 F.3d 938 (8th Cir.) (firearm possessed "in connection with" drug possession if it facilitated or had potential to facilitate)
United States v. Sneed, 742 F.3d 341 (8th Cir.) (reversal required if district court applies enhancement based solely on temporal/spatial nexus without the "facilitate" finding)
United States v. Dalton, 557 F.3d 586 (8th Cir.) (articulates limits on applying § 2K2.1 enhancement based only on proximity)
United States v. Jarvis, 814 F.3d 936 (8th Cir.) (upholds "in connection with" finding where defendant carried heroin and gun together in public)
United States v. Swanson, 610 F.3d 1005 (8th Cir.) (permissible to infer gun was for protection of drugs when amount exceeds residue)