United States v. Columbus Lawrence, No. 20-2128 (8th Cir. 2021)

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Court Description: [Per Curiam - Before Grasz, Wollman, and Stras, Circuit Judges] Criminal case - Sentencing. Anders case. The district court did not err in applying a four-level enhancement under Guidelines Sec. 2K2.1(b)(6)(B) - see U.S. v. Walker, 771 F.3d 339, 452-453 (8th Cir. 2014).

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United States Court of Appeals For the Eighth Circuit ___________________________ No. 20-2128 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Columbus Tre Lawrence, also known as Tre, also known as Country Lawrence lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Northern District of Iowa - Eastern ____________ Submitted: February 26, 2021 Filed: March 4, 2021 [Unpublished] ____________ Before GRASZ, WOLLMAN, and STRAS, Circuit Judges. ____________ PER CURIAM. Columbus Lawrence appeals the sentence the district court1 imposed after he pled guilty to a firearm offense. His counsel has moved to withdraw, and has filed 1 The Honorable C.J. Williams, United States District Judge for the Northern District of Iowa. a brief under Anders v. California, 386 U.S. 738 (1967), challenging the district court’s application of United States Sentencing Guidelines Manual § 2K2.1(b)(6)(B)’s four-level enhancement to Lawrence’s advisory offense level for possession of a firearm in connection with another felony offense (Iowa Code § 724.4(1)). Lawrence argues the district court erred in imposing the enhancement because the conduct leading to his conviction was the same conduct by which he could be held accountable under section 724.4(1). As Lawrence acknowledges, this argument is foreclosed by our decision in United States v. Walker, 771 F.3d 449, 452-53 (8th Cir. 2014); see also United States v. Manning, 786 F.3d 684, 686 (8th Cir. 2015) (“A panel of this Court is bound by a prior Eighth Circuit decision unless that case is overruled by the Court sitting en banc.”). Further, having independently reviewed the record under Penson v. Ohio, 488 U.S. 75 (1988), we find no non-frivolous issues for appeal. Accordingly, we grant counsel’s motion and affirm. ______________________________ -2-

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