United States v. Jones, 628 F.3d 1044

Jones pleaded guilty to conspiracy to distribute crack and powder cocaine and was sentenced to 151 months; district court added two-level dangerous-weapon enhancement, then gave a three-level reduction for acceptance of responsibility, for a total offense level of 31.
Base offense level for conspiracy was 32; weapon enhancement elevated it to 34; with acceptance, total level was 31; Criminal History Category IV yielded a 151–181 month advisory range.
Jones was on probation for a 2007 state conviction for possession of a firearm by a felon; probation violation led to a separate state prison term of 3–6 years in February 2009.
In February 2009, a federal grand jury indicted Jones for conspiracy to distribute 50g+ crack cocaine and 500g+ powder cocaine and for possession with intent to distribute, with two additional counts later dismissed after the guilty plea.
The district court sentenced Jones to 151 months concurrent with the state sentence and did not credit him for time served in state custody before the federal sentence.
On appeal, Jones challenged (1) the dangerous-weapon enhancement and (2) the failure to credit time served under 5G1.3.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the weapons enhancement was valid.	Jones asserts the district court erred in finding a firearm possessed in furtherance of the conspiracy.	Jones contends Reynolds and Swift credibility issues render the enhancement unreliable.	No clear error; credibility affirmed and weapon enhancement affirmed.
Whether credit for state custody time was misapplied under 5G1.3.	Jones argues court should credit time as concurrent with the state sentence from an earlier date.	Jones argues 5G1.3(b) should apply to credit time served for a related offense.	District court correctly applied 5G1.3(c); no credit for time prior to federal sentence under 5G1.3(b).

United States v. Anderson, 618 F.3d 873 (8th Cir. 2010) (guideline 2D1.1 dangerous-weapon enhancement review)
United States v. Boyce, 564 F.3d 911 (8th Cir. 2009) (cooperation agreements and witness credibility considerations)
United States v. Johnson, 601 F.3d 869 (8th Cir. 2010) (claim of credibility review is highly deferential)
United States v. Hakim, 491 F.3d 843 (8th Cir. 2007) (extreme circumstances for challenging credibility)
United States v. Fifield, 432 F.3d 1056 (9th Cir. 2005) (relevance of conduct to probation-violation issues under 5G1.3)
United States v. Broadnax, 536 F.3d 695 (7th Cir. 2008) (interpretation of 5G1.3 relevant conduct concept)
United States v. Burch, 406 F.3d 1027 (8th Cir. 2005) (5G1.3(b) relevant conduct analysis for crediting time served)