United States v. Oscar Canamore, 916 F.3d 718

Defendant Oscar Canamore pled guilty to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). He had two prior felony convictions barring firearm possession.
Law enforcement found a .22 semiautomatic pistol in pants in his bedroom, ammunition, marijuana, and a pawn ticket linking him to a separately pawned stolen .38 revolver.
An Arkansas theft-by-receiving warrant had been issued relating to the pawned stolen firearm.
At sentencing the district court set a base offense level of 24, applied +2 under U.S.S.G. § 2K2.1(b)(4)(A) for possession of a stolen firearm and +4 under § 2K2.1(b)(6)(B) for possessing a firearm in connection with another felony, then granted a 3-level reduction for acceptance, yielding offense level 27 and Guidelines range 100–120 months (statutory cap 120 months).
The district court found the combined enhancements produced a harsh range, varied downward for fairness, and imposed 84 months’ imprisonment. Canamore appealed the guideline calculation and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether applying both § 2K2.1(b)(4)(A) (stolen firearm) and § 2K2.1(b)(6)(B) (firearm in connection with another felony) results in impermissible double counting	Canamore: applying both enhancements "double counts" the same conduct and improperly increases punishment	Government: the subsections are conceptually distinct, each furthers an independent sentencing purpose, so both may apply	Court affirmed: no impermissible double counting; both enhancements properly applied
Whether the 84-month sentence was an abuse of discretion despite a below-Guidelines variance	Canamore: implied that sentence remained excessive given overlap and circumstances	Government: district court reasonably weighed factors and permissibly varied downward from the advisory range	Court affirmed: no abuse of discretion in imposing 84 months

United States v. Chapman, 614 F.3d 810 (8th Cir. 2010) (standard for reviewing Guidelines application and double-counting questions)
United States v. Hipenbecker, 115 F.3d 581 (8th Cir. 1997) (double-counting explained; permissible if Commission intended and sections serve independent purposes)
United States v. Kenney, 283 F.3d 934 (8th Cir. 2002) (upholding application of both stolen-firearm and related-enhancement provisions)
United States v. Hedger, 354 F.3d 792 (8th Cir. 2004) (affirming both possession-of-stolen-firearm and possession-in-connection-with-another-felony enhancements)
United States v. Carr, 895 F.3d 1083 (8th Cir. 2018) (noting that a below-Guidelines variance is rarely an abuse of discretion)
United States v. Zauner, 688 F.3d 426 (8th Cir. 2012) (cited for principle on reviewing downward variances)