Case Explained: United States of America v. Jesus Salamo-Roche

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-07-30 The eighth-circuit affirmed the district court’s application of a two-level offense enhancement for possessing a dangerous weapon under U.S.S.G. § 2D1.1(b)(1) in a methamphetamine conspiracy case. The court applied de novo review to the guideline application and clear error review to factual findings, utilizing the standard that the enhancement applies if the weapon was present unless it is clearly improbable that it was connected with the offense. The court held that the government met its low burden by showing the firearm was found in a vehicle at the defendant’s home, which served as a meeting location for the conspiracy and where the defendant stored weapons for co-conspirators. The court reasoned that constructive possession includes dominion over premises and that firearms are known tools of narcotics dealing, making it not clearly improbable that the weapon was connected to the drug trade. The practical consequence is that the defendant’s conviction and sentence stand. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.