United States v. Gattis, No. 16-4663 (4th Cir. 2017)Annotate this Case
The Fourth Circuit affirmed defendant's sentence after he pleaded guilty to possession of a firearm by a felon. The court held that defendant's prior North Carolina common law robbery conviction categorically qualified as a felony conviction for a crime of violence, as provided in USSG 2K2.1(a)(4)(A) and defined in USSG 4B1.2(a). The court also held that the evidence was sufficient to support the district court's application of a two-level enhancement under USSG 2K2.1(b)(1)(A), based on the number of weapons involved in the offense, and a four-level enhancement under USSG 2K2.1(b)(6)(B), based on the use or possession of a firearm or ammunition in connection with another felony offense.