United States v. Ronnie Wellington, 468 F. App'x 529

Wellington pled guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
Loaded, cocked handgun found in front of driver’s seat; drugs (49 tablets) found under the same seat.
Gun and drugs found close proximity; gun was loaded and ready to use.
District court applied § 2K2.1(b)(6) for possession of a firearm in connection with another felony (drug distribution).
Guideline range 110–120 months; district court sentenced Wellington to 110 months.
Wellington appeals only the § 2K2.1(b)(6) enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is there a nexus between firearm and another felony for § 2K2.1(b)(6)?	Wellington argues no nexus.	Government argues fortress-like nexus supported by proximity and trafficking.	Yes; nexus established.
Was the nexus properly found given fortress theory and drug trafficking evidence?	Wellington contests sufficiency of evidence tying gun to trafficking.	Government adduces proximity, quantity, and packaging as trafficking indicators.	District court’s nexus finding supported; enhancement proper.
Does personal-protection claim negate nexus?	Wellington claims gun protected him personally.	Evidence shows readiness to use gun during felony activity.	Fortress factors outweigh personal-protection allegation; nexus valid.

United States v. Taylor, 648 F.3d 417 (6th Cir. 2011) (guidelines-sentencing review; nexus standard)
United States v. Angel, 576 F.3d 318 (6th Cir. 2009) (nexus between firearm and independent felony)
United States v. Huffman, 461 F.3d 777 (6th Cir. 2006) (fortress theory application)
United States v. Richardson, 510 F.3d 622 (6th Cir. 2007) (gun-drugs proximity supports nexus)
United States v. Hardin, 248 F.3d 489 (6th Cir. 2001) (proximity evidence indicating trafficking)
United States v. Shields, 664 F.3d 1040 (6th Cir. 2011) (factors suggesting lack of nexus)
United States v. McKenzie, 410 F. App’x 943 (6th Cir. 2011) (limitations on fortress-based nexus)