United States v. Justin Blalock, 689 F. App'x 263

Defendant Justin Blalock was convicted by a jury of possessing a firearm during a drug-trafficking offense and sentenced to the 60‑month statutory minimum plus two years supervised release.
Blalock admitted selling about one pound of marijuana per week and having ~2 pounds at home when searched.
Two loaded handguns were found immediately accessible in a bedside table; a small bag of marijuana and cash were in the same room.
Blalock claimed the guns were for hunting/sport and protection; the guns were loaded, not secured, and readily accessible.
The search that discovered the guns and drugs was pursuant to a warrant based on suspected drug activity.
On appeal Blalock argued the evidence was insufficient to show the firearms were possessed in furtherance of drug trafficking. The court reviewed the sufficiency of evidence de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence showed firearms were possessed in furtherance of drug trafficking	Government: accessible, loaded guns near drugs and cash support inference of furtherance	Blalock: guns kept for sport/protection; not in same room as majority of drugs; insufficient nexus	Affirmed — viewing evidence in favor of Government, sufficient for conviction

United States v. Klein, 543 F.3d 206 (5th Cir. 2008) (standard of de novo review for sufficiency challenges)
United States v. Ceballos-Torres, 218 F.3d 409 (5th Cir. 2000) (sets multi‑factor test for when a firearm is possessed in furtherance of drug trafficking)
United States v. Palmer, 456 F.3d 484 (5th Cir. 2006) (contrast: firearm secured, unloaded, stored separately weighs against furtherance finding)
United States v. Garcia, 567 F.3d 721 (5th Cir. 2009) (jury may choose among reasonable constructions of the evidence)
United States v. Riggins, [citation="524 F. App'x 123"] (5th Cir. 2013) (accessible, loaded firearms near drug activity support inference of furtherance)