Case Explained: UNITED STATES OF AMERICA v. MARKEEMEIUS DESHAUN MORGAN

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-29 The Fourth Circuit affirmed the defendant’s 66-month sentence imposed for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1). The court applied a clear error standard to review the district court’s factual findings and de novo review for legal conclusions, holding that the government met its burden of establishing the applicability of sentencing enhancements by a preponderance of the evidence. Specifically, the court found no clear error in the district court’s determination that Morgan possessed a semiautomatic firearm capable of accepting a large capacity magazine under U.S.S.G. § 2K2.1(a)(4)(B) and that an enhancement applied for possession in connection with another felony offense under U.S.S.G. § 2K2.1(b)(6). The court relied on the presumption of facilitation, which applies when a firearm and drugs are found in close proximity during a drug trafficking crime, citing *United States v. Mitchell*, 78 F.4th 661 (4th Cir. 2023), to support the finding that the gun was possessed in connection with the dealer quantities of cocaine recovered from Morgan’s vehicle. As a result, the judgment of the district court remains in effect, and the defendant’s sentence is upheld without oral argument. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.