US v. Jason Dix, No. 19-4725 (4th Cir. 2023)
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When a deputy sheriff in Lexington County, South Carolina, began to follow a vehicle because he thought the driver was behaving suspiciously, the vehicle sped away, failing to stop when the deputy activated his patrol car’s blue light and siren and leading the deputy on a high-speed chase. After the vehicle crashed, the driver, identified as Defendant, was arrested and a firearm and ammunition were recovered from the front floorboard of the driver’s side of the vehicle. Defendant pleaded guilty to possession of a firearm by a convicted felon, and the district court sentenced him to 99 months imprisonment. The 99-month sentence included an enhancement under U.S.S.G. Section 2K2.1(b)(6)(B) for the use or possession of the firearm “in connection with another felony offense,” namely failure to stop for a blue light. At sentencing, Defendant objected to the enhancement on both procedural and substantive grounds.
The Fourth Circuit agreed. The court explained that the district court erred in relying on the blue-light offense to apply a Section 2K2.1(b)(6)(B) enhancement when Defendant received notice of that basis for the first time at the sentencing hearing. However, the court also concluded that the error was, in the circumstances of this case, harmless. Finally, the court concluded that the district court did not clearly err in applying the enhancement when the firearm was lying at Defendant’s feet while he failed to stop for a blue light.
This opinion or order relates to an opinion or order originally issued on February 14, 2023.
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