United States v. Ingram, No. 21-3305 (7th Cir. 2022)

Granite City Police officers conducted a traffic stop in a known drug-trafficking area and found Ingram, a passenger in the vehicle, in possession of a loaded handgun and small quantities of methamphetamine and cocaine. Ingram pleaded guilty to unlawfully possessing a firearm as a felon. At sentencing, the district judge added four offense levels to the Guidelines calculation after finding that Ingram possessed the firearm “in connection with” another felony—namely, felony drug possession, U.S.S.G. 2K2.1(b)(6)(B). The judge then sentenced Ingram to 72 months in prison, an upward variance from the 46-57 months advisory range.

The Seventh Circuit affirmed. Ingram possessed both the handgun and drugs as he left a known drug-trafficking area and fled on foot when the police initiated the traffic stop. From these facts, the judge found that Ingram’s handgun facilitated his drug possession. That finding was not clearly erroneous, making the application of the enhancement proper. Nor did the judge abuse his discretion with the upward variance, which was justified by Ingram’s criminal history and dangerous conduct during his arrest.