| In February 2018, a confidential informant purchased 14.18 grams of methamphetamine from West for $300 in a Walmart restroom. Two months later, the same confidential informant met West inside a Meijer restroom and paid West $900 for 116.112 grams of simulated methamphetamine. Leaving Meijer, West entered the rear passenger side of a vehicle in which the driver’s seat was occupied by Johnson. Johnson’s girlfriend sat in the front passenger seat. Officers stopped and searched the vehicle, discovering a semi-automatic pistol under the front passenger seat. West was charged with knowingly and intentionally distributing methamphetamine in February 2018, 21 U.S.C. 841(a)(1), and for being a felon in possession of a firearm in April 2018, 18 U.S.C. 922(g)(1). West pleaded guilty to the drug charge; the government dismissed the felon-in-possession charge. The district court determined that West’s base offense level should be increased by two levels under U.S.S.G. 2D1.1(b)(1) because a firearm was possessed in relation to West’s drug-related offense, resulting in a Guidelines range of 37-46 months. The Sixth Circuit affirmed West’s 40-month sentence. The court rejected arguments that the district court abused its discretion in determining that he possessed the gun found in the vehicle and that the transaction was not “relevant conduct” under U.S.S.G. 1B1.3(a)(2). The district court adequately considered the 18 U.S.C. 3553(a) factors. |
