United States v. Lamont Long, Jr., 701 F. App'x 286

Lamont Long, Jr. pled guilty (no plea agreement) to conspiracy to distribute and possess with intent to distribute ≥28 grams of cocaine base under 21 U.S.C. §§ 841(a)(1), (b)(1)(B), 846.
District court applied a two-level Sentencing Guidelines enhancement under USSG § 2D1.1(b)(1) for possession of a dangerous weapon (firearm).
The government relied on transcripted calls by Long to coconspirators (March 25–26, 2013) to show a temporal and spatial nexus between the firearm and drug activity.
Long challenged the firearm enhancement on appeal, arguing the enhancement was not supported; he also attempted to raise an uncorroborated-statement/corroboration argument for the first time on appeal.
The Fourth Circuit reviewed for clear error, concluded the enhancement was supported, and held any potential error was harmless because the district court would have imposed the same variant sentence under 18 U.S.C. § 3553(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a two-level firearm enhancement under USSG § 2D1.1(b)(1) was properly applied	Long argued the government failed to prove the weapon was possessed in connection with the drug offense	Government argued transcripts and circumstantial evidence showed temporal/spatial nexus and constructive possession	Court affirmed: enhancement not clearly erroneous; nexus shown by calls and circumstantial evidence
Whether new corroboration-based arguments may be considered on appeal	Long sought to raise a new argument about corroboration of his statements	Government opposed as forfeited/later-raised issue	Court refused to consider new argument absent exceptional circumstances
If enhancement error occurred, whether it was harmless	Long contended any error affected Guidelines and sentence	Government argued district court said it would impose same sentence as a variance, and sentence was reasonable under § 3553(a)	Court held any error harmless: district court would have imposed same term and variance was reasonable
Standard of review for § 2D1.1(b)(1) application	Long implicitly sought de novo review of sufficiency	Government relied on clear-error standard	Court applied clear-error review for factual application of enhancement

United States v. Manigan, 592 F.3d 621 (4th Cir. 2010) (constructive possession and circumstantial evidence can support firearm enhancement)
United States v. Bolton, 858 F.3d 905 (4th Cir. 2017) (government must show temporal and spatial relation; harmless-error framework for guideline mistakes)
In re Under Seal, 749 F.3d 276 (4th Cir. 2014) (appellate courts generally do not consider issues raised first on appeal absent exceptional circumstances)