United States v. Everett Jackson, 997 F.3d 1138

July 26, 2018: a confidential informant, arranged by law enforcement, went to Everett Jackson’s apartment expecting to buy both heroin and a firearm; Jackson delivered six grams of heroin and accepted $650 but said he did not then have the firearm.
Jackson promised to obtain the gun; on August 1 (under law-enforcement supervision) he provided a firearm to the same informant at his apartment and was paid $700; the informant then completed a separate heroin purchase from Sheldon Rice.
Jackson was arrested and pleaded guilty to possession of heroin with intent to distribute and being a felon in possession of a firearm.
The district court applied a four-level enhancement under U.S.S.G. § 2K2.1(b)(6)(B) (possession/use of a firearm "in connection with" another felony), finding a sufficient connection between the July 26 heroin sale and the firearm transaction, and concluded the August 1 heroin sale was not relevant conduct for Jackson.
The enhancement raised Jackson’s Guidelines range from 37–46 months to 57–71 months; the court sentenced him to 57 months’ imprisonment and three years’ supervised release.
On appeal the Eleventh Circuit reviewed the Guidelines interpretation de novo and facts for clear error and affirmed the enhancement and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether U.S.S.G. § 2K2.1(b)(6)(B) applies — i.e., did Jackson possess a firearm "in connection with" a felony (heroin sale)?	Government: Yes — the drug and gun sales were negotiated as a joint transaction and coordination facilitated the drug sale.	Jackson: No — transactions were separate (different seller involvement), gun was delivered days later, and separate prices show independent transactions.	The court affirmed: enhancement applies; planned, coordinated sales (and Jackson’s conduct) show sufficient connection.
Whether temporal delay or separate seller/pricing defeats the "in connection with" finding.	Government: Delay and separate price do not negate the original plan to conduct a combined transaction; coordination still facilitated the drug sale.	Jackson: The gap in delivery, Rice’s role, and separate consideration show no facilitating link.	The court held these facts do not render the finding clearly erroneous; the original joint plan and conduct supported the enhancement.

United States v. Ryan, 935 F.3d 40 (2d Cir. 2019) (adding a firearm to a drug sale can facilitate the drug transaction)
United States v. Darryl Jackson, 877 F.3d 231 (6th Cir. 2017) (firearm sales can make drug purchases more efficient and reduce detection risk)
United States v. Carillo-Ayala, 713 F.3d 82 (11th Cir. 2013) (a "package deal" can show a sufficient connection but is not the only basis for enhancement)
United States v. Martinez, 964 F.3d 1329 (11th Cir. 2020) (possession "in connection with" another felony is a factual finding reviewed for clear error)
United States v. Dimitrovski, 782 F.3d 622 (11th Cir. 2015) (Sentencing Guidelines interpretation reviewed de novo)