United States v. Watkins, No. 22-3564 (8th Cir. 2024)
Annotate this CaseThe defendant, Henry Watkins Jr., was stopped while driving by a police officer due to a mismatched license plate. Upon approaching the vehicle, the officer smelled marijuana and eventually found cocaine, ecstasy, and a loaded 9-millimeter handgun in the vehicle. Watkins was the sole occupant at the time. He was subsequently indicted and convicted for being a felon in possession of a firearm. Watkins appealed his conviction and sentence, arguing that the evidence was insufficient to support his conviction and that there were errors in his sentencing. The United States Court of Appeals for the Eighth Circuit found sufficient evidence for the conviction, as Watkins was the only person in the vehicle and made movements consistent with hiding the gun. Therefore, the court affirmed Watkins's conviction. However, the court found procedural errors in Watkins's sentencing, as the district court presumed the Guidelines range to be reasonable and adopted a sentence without considering the factors in § 3553(a). The court vacated Watkins's sentence and remanded the case for resentencing consistent with its opinion.
Court Description: [Shepherd, Author, with Kelly and Stras, Circuit Judges] Criminal case - Criminal law and Sentencing. The evidence was sufficient to support defendant's conviction for being a felon in possession of a firearm; the district court did not err in applying an enhancement under Guidelines Sec. 2K2.1(b)(6) based on its finding that possession of the firearm facilitated defendant's drug possession; the district court did not err in increasing defendant's base offense level under Guidelines Sec. 2K2.1(a)(2) from 20 to 24 based on his prior Arkansas controlled-substance conviction; the district court plainly erred in presuming the guidelines range was reasonable and in adopting a sentence without considering the 3553(a) factors; these procedural errors, coupled with the fact that the court had previously granted defendant a 60-month downward variance, demonstrate a reasonable probability that defendant would have received a lighter sentence but for the errors; defendant's conviction is affirmed, but his sentence is vacated, and the matter is remanded for resentencing consistent with this opinion.
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