United States v. Henry Walker, 828 F.3d 352

Defendant Henry David Walker pleaded guilty without a plea agreement to: conspiracy to distribute methamphetamine; possession of a firearm in furtherance of a drug-trafficking crime (18 U.S.C. § 924(c)(1)(A)); and being a felon in possession of firearms.
At rearraignment Walker admitted agents intercepted communications identifying him as a meth supplier, and that he possessed multiple firearms and about one pound of 96% pure methamphetamine seized from his residence.
Agents recovered approximately nine firearms of various types from Walker’s home; Walker was a convicted felon at the time.
The district court accepted the guilty plea and sentenced Walker to concurrent terms (151 months) on the drug and felon-in-possession counts and a consecutive mandatory 60-month term under § 924(c).
On appeal Walker challenges only the § 924(c) conviction, arguing the factual basis was insufficient to show the firearms were possessed "in furtherance" of drug trafficking.
The Fifth Circuit reviews this unpreserved challenge for plain error and affirms, finding the admitted facts adequate to support the § 924(c) conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether factual basis supported § 924(c) conviction	Government: admissions and facts show firearms possessed in furtherance of drug trafficking	Walker: factual basis lacked evidence on proximity, accessibility, loaded status, or ammunition linking guns to drugs	Affirmed – admitted facts (large quantity of high-purity meth, multiple firearms, illegal possession by felon) sufficient under plain-error review
Whether mere presence of guns suffices for § 924(c)	N/A	Walker: mere presence without other linking facts is insufficient	Court: mere presence not enough generally, but here other facts made Ceballos-Torres factors met sufficiently
Whether all Ceballos-Torres factors must be present	Government: not required; some factors suffice	Walker: absence of several factors undermines conviction	Held: not all factors required; courts assess totality and applicable factors support conviction
Whether plain-error standard allows reversal	Walker: error was clear and affected substantial rights	Government: no plain error; factual basis adequate	Held: no plain error; requirements not met to overturn plea acceptance

United States v. Ceballos-Torres, 218 F.3d 409 (5th Cir. 2000) (possession is in furtherance when it furthers or advances drug trafficking; lists helpful factors)
United States v. Palmer, 456 F.3d 484 (5th Cir. 2006) (reversed § 924(c) conviction where gun was secured in a safe, unloaded, and not tied to drug activity)
United States v. Marek, 238 F.3d 310 (5th Cir. 2001) (plain-error review framework for unpreserved Rule 11/factual-basis challenges)
United States v. Charles, 469 F.3d 402 (5th Cir. 2006) (affirmed § 924(c) conviction based on some but not all Ceballos-Torres factors)
United States v. Adams, 961 F.2d 505 (5th Cir. 1992) (court must ensure an adequate factual basis supports a guilty plea)