United States v. Miguel Alaniz, 69 F.4th 1124

Alaniz sold cocaine three times in 2021 to a confidential informant; officers stopped his car and found a loaded handgun in the vehicle.
A subsequent search of his home uncovered ~47 grams of cocaine, scales with residue, and 12 firearms (including AR-15 and AK-47 style rifles).
Alaniz pleaded guilty to multiple counts of distribution and possession with intent to distribute cocaine under 21 U.S.C. § 841.
The presentence report recommended a two-level enhancement under U.S.S.G. § 2D1.1(b)(1) (possession of a dangerous weapon) and a downward safety-valve departure under § 5C1.2(a)(2) / §2D1.1(b)(18).
At sentencing the court applied the § 2D1.1(b)(1) enhancement, granted safety-valve relief, imposed a total offense level of 15, and sentenced Alaniz to 15 months; Alaniz appealed solely contesting the constitutionality of § 2D1.1(b)(1) under Bruen.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether U.S.S.G. § 2D1.1(b)(1) (2‑level enhancement for possession of a dangerous weapon during a drug felony) violates the Second Amendment under Bruen	The government: Bruen step one assumed met; § 2D1.1(b)(1) is consistent with a longstanding historical tradition of enhancing punishment when weapons are possessed during dangerous felonies	Alaniz: Enhancement punishes lawful possession; historical analogues are not sufficiently similar (possession was often an element then), and drug trafficking is a modern offense with different societal concerns	Court assumed step one but held Bruen step two satisfied — historical analogues of enhancing penalties for weapon possession during felonies are sufficiently similar; § 2D1.1(b)(1) is constitutional; affirmed

New York State Rifle & Pistol Ass'n, Inc. v. Bruen, 142 S. Ct. 2111 (2022) (adopts text-and-history test for Second Amendment challenges)
District of Columbia v. Heller, 554 U.S. 570 (2008) (recognizes individual right to possess firearms for self-defense)
McDonald v. City of Chicago, 561 U.S. 742 (2010) (applies Second Amendment protections against the states via the Fourteenth Amendment)
Konigsberg v. State Bar of Cal., 366 U.S. 36 (1961) (quoted for presumption that text covers conduct)
United States v. Nelson, 222 F.3d 545 (9th Cir. 2000) (interpreting § 2D1.1(b)(1) to apply when a weapon was present)
United States v. Chovan, 735 F.3d 1127 (9th Cir. 2013) (discussing prior two-step Second Amendment framework)
United States v. Vongxay, 594 F.3d 1111 (9th Cir. 2010) (de novo review of constitutional issues)
Gonzales v. Raich, 545 U.S. 1 (2005) (discussing modern nature of federal drug regulation)
Jackson v. City & County of San Francisco, 746 F.3d 953 (9th Cir. 2014) (discussing burdens on core Second Amendment rights)
United States v. Zamora, 37 F.3d 531 (9th Cir. 1994) (recognizing increased risk of violence when guns are present during drug trafficking)