United States v. Ready, No. 22-3101 (8th Cir. 2023)
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In this case before the United States Court of Appeals for the Eighth Circuit, the defendant, Bradley Ready, appealed his sentence following his guilty plea for possession with intent to distribute methamphetamine and possession of a firearm as an unlawful user of a controlled substance. The court affirmed the district court's decision.
During a search of Ready's residence, law enforcement officers found drug paraphernalia, scales, a loaded hunting rifle, and three bags of methamphetamine. Ready was subsequently charged and pleaded guilty to both counts. At sentencing, the U.S. Probation Office recommended grouping the drug and gun counts together and applying a two-level enhancement due to the possession of a dangerous weapon. Ready objected to this enhancement, but the district court overruled this objection.
On appeal, Ready argued that the district court erred in applying the enhancement for possession of a dangerous weapon and applied the wrong standard in determining his eligibility for safety valve relief. The appellate court found no error in the district court's conclusions.
The appellate court held that the district court did not err in applying the enhancement for possession of a dangerous weapon, as it was not "clearly improbable" that the rifle found in Ready's bedroom was connected to the distribution of methamphetamine from his home. The court also held that the district court did not err in its application of the standard for determining Ready's eligibility for safety valve relief. Therefore, the district court's judgment was affirmed.
Court Description: [Per Curiam - Before Shepherd, Kelly, and Stras, Circuit Judges] Criminal case - Sentencing. The district court did not err in applying an enhancement under Guidelines Sec. 2D1.1(b)(1) for possession of a dangerous weapon; the district court did not err in considering defendant's possession of a handgun and drugs in an earlier incident as the information was relevant to establish the nature of the connection between drugs and the rifle found in his room a few days later, which incident is the basis for this prosecution; it was not clearly improbable that the rifle found in the bedroom was connected to defendant's distribution of meth from his home; the district court did not plainly err in determining defendant was not eligible for safety-valve relief.
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