United States v. Mason, No. 11-544 (2d Cir. 2012)Annotate this Case
Defendant appealed from his 33-year sentence after he pleaded guilty to being a felon in possession. Defendant argued that the district court erred in denying him a sentencing reduction under the "lawful sporting purposes" provision of the Sentencing Guidelines. The court held that the proper focus of the inquiry whether a defendant was eligible for the "lawful sporting purposes" reduction was the defendant's purpose for possessing the firearm, determined by considering all relevant surrounding circumstances. By focusing exclusively on defendant's actual use of the firearms he possessed, the district court misinterpreted the Guidelines, but the court concluded that the error was harmless because the district court would have denied the reduction absent any error.