United States v. Quentin Gray, No. 10-3090 (8th Cir. 2011)
Annotate this CaseDefendant pled guilty to being a felon in possession of a firearm and was sentenced to 108 months in prison followed by three years of supervised release. At issue was whether the district court erred in applying a cross reference under the sentencing guidelines and in converting cash to its drug equivalent for purposes of calculating the drug quantity in the offense. The court affirmed and held that the district court did not clearly err in finding that defendant possessed a firearm in connection with drug trafficking where there was sufficient evidence to support the court's finding that he possessed a Glock handgun in connection with a drug trafficking offense, which properly triggered the cross reference under the sentencing guidelines. The court also held that evidence amply supported the conclusion that the conversion of cash helped to reflect the scale of defendant's underlying drug trafficking offense more accurately, which was all the guidelines required.
Court Description: Criminal case - Sentencing. Application of the Guidelines Sec. 2K2.1(c)(1) cross reference was not clearly erroneous; no error in converting cash into its crack equivalent.
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