United States v. Oquendo, 23-6640

Ramon Oquendo was convicted by a jury in the District of Connecticut of five offenses, including trafficking in fentanyl and cocaine, firearm-related crimes, and possession of ammunition as a felon.
The conviction involved significant quantities of drugs, a firearm, ammunition, and cash, all seized from Oquendo’s residence during the execution of a search warrant.
Oquendo received a total effective sentence of ten years in prison and five years of supervised release.
On appeal, Oquendo challenged the constitutionality of his conviction for possessing ammunition as a felon under 18 U.S.C. § 922(g)(1), citing the Supreme Court’s decision in Bruen.
He also argued the evidence was insufficient to sustain his conviction for possessing a firearm in furtherance of a drug trafficking crime, as the gun was unloaded and wrapped in cellophane.

Issue	Oquendo's Argument	Government's Argument	Held
Constitutionality of § 922(g)(1) post-Bruen	§ 922(g)(1) violates Second Amendment after Bruen	Precedent upholds § 922(g)(1); Bruen didn’t overturn it	Statute remains constitutional
Sufficiency of evidence for 18 U.S.C. § 924(c) conviction	Unloaded gun not readily accessible or operable for trafficking	Nexus existed: gun, ammo, drugs, and cash found together	Sufficient evidence for conviction

United States v. Bogle, 717 F.3d 281 (2d Cir. 2013) (upheld constitutionality of felon-in-possession statute pre-Bruen)
United States v. Finley, 245 F.3d 199 (2d Cir. 2001) (unloaded firearm found near drugs can support conviction under § 924(c))
United States v. Snow, 462 F.3d 55 (2d Cir. 2006) (provides factors for nexus between firearm and drug trafficking crime)
United States v. Lewter, 402 F.3d 319 (2d Cir. 2005) (defines "in furtherance" standard under § 924(c))