United States v. Brown, No. 23-1212 (6th Cir. 2023)
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Brown created a driver’s license with his photo and someone else’s identity and made credit cards using that identity, pulling account numbers from the dark web. Brown used those fraudulent documents to purchase 25 firearms, which he sold. Brown subsequently walked into a gun store, picked out a firearm, and presented a fraudulent license and credit card. The store employee recognized Brown and called the police. As police arrived, Brown drove away in a rented U-Haul. During the ensuing traffic stop, officers found Brown’s fraudulent license and false credit cards in a wallet on the passenger seat; a gun that had been reported stolen was between the front seats. After being arrested, Brown recruited a friend to continue his scheme. The friend used fraudulent cards to purchase 39 firearms. The two fraudulently purchased $56,000 in guns over three months.
Brown pled guilty to aggravated identity theft, using a false ID during the purchase of a firearm, and conspiracy to commit wire fraud, 18 U.S.C. 922(a)(6), 1028A(a)(1), 1343, 1349. The court enhanced Brown’s sentencing range based on the stolen firearm in the U-Haul, U.S.S.G. 2K2.1(b)(4)(A), and imposed a 120-month sentence. The Sixth Circuit affirmed, noting that the enhancement would apply even without the stolen firearm in the U-Haul. Fraudulently purchased firearms are “stolen” for purposes of the enhancement.
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