United States v. Ryan, No. 17-3919 (2d Cir. 2019)Annotate this Case
The Second Circuit held that a district court may apply a four-level sentencing enhancement under USSG 2K2.1(b)(6)(B) to a defendant who sells a firearm and drugs to a buyer in a single transaction, and to a buyer who the defendant has reason to believe is a drug dealer. The court considered Defendant Wood's remaining arguments and held that they were without merit. Accordingly, the court affirmed with respect to Defendant Wood in Appeal No. 18-985. The court affirmed the consolidated appeal of Defendant Ryan in a simultaneously filed summary order.