United States v. Guadalupe Urbina-Rodriguez, 986 F.3d 1095

Defendant Guadalupe Urbina-Rodriguez was convicted of (1) possession with intent to distribute ≥50 g methamphetamine, (2) possessing a firearm in furtherance of a drug-trafficking crime (18 U.S.C. § 924(c)(1)(A)), and (3) being a felon in possession of a firearm.
Postal inspectors had identified a package from California as containing controlled substances; Urbina-Rodriguez personally accepted that package at his rural Missouri home, claiming to be “Jose.”
Officers executed a search warrant within one to two minutes of delivery; they found Urbina-Rodriguez seated on his front lawn, the methamphetamine package on a nearby chair, and a loaded Marlin .22 rifle resting against a tree immediately adjacent to him.
The package contained 430.8 grams of actual methamphetamine; investigators found a pattern of twelve prior packages to the same address over seven months; Urbina-Rodriguez admitted receiving similar packages and had prior meth-trafficking convictions.
Urbina-Rodriguez claimed the rifle was for protection of his chickens; his wife told officers that two women typically arrived after such deliveries. The jury rejected his explanation; the district court denied a new trial and judgment of acquittal.
On appeal, the Eighth Circuit reviewed sufficiency of the evidence (highly deferential standard) and whether expert testimony was required to establish the § 924(c) nexus.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved the firearm was possessed in furtherance of drug trafficking under § 924(c)	Circumstantial facts—immediate proximity of loaded rifle to newly delivered, high-value drugs; prior deliveries and admissions; prior trafficking convictions; wife’s statement—permit reasonable inference of nexus	The rifle was used only to protect chickens; its proximity to the drugs was coincidental; evidence insufficient	Affirmed: a reasonable juror could find the required nexus based on the totality of circumstantial evidence
Whether the government was required to present expert testimony to show the nexus	Expert testimony is not required; the government may rely on circumstantial evidence and common-sense inferences	Government needed expert to "connect the dots" between firearm possession and drug trafficking	Affirmed: expert testimony not required; jury may infer nexus from the facts presented

United States v. Fetters, 698 F.3d 653 (8th Cir. 2012) (articulates deferential sufficiency-of-the-evidence standard on appeal)
United States v. Druger, 920 F.3d 567 (8th Cir. 2019) (nexus for § 924(c) may be established in a variety of ways)
United States v. Saddler, 538 F.3d 879 (8th Cir. 2008) (affirmed § 924(c) conviction without expert testimony where proximity supported inference)
United States v. Urkevich, 408 F.3d 1031 (8th Cir. 2005) (proximity and ready availability of firearms support inference they were to protect drugs)
United States v. Hilliard, 490 F.3d 635 (8th Cir. 2007) (mere simultaneous possession of drugs and firearms is insufficient to establish nexus)