Case Explained: United States v. Jackson

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-06-16 Docket: 5:24-CR-00368-J-1) The Tenth Circuit affirmed the district court’s imposition of two sentencing enhancements under U.S.S.G. § 2K2.1 on Darrius Jackson, a defendant convicted of felon in possession of a firearm. The court held that the district court properly applied a two-level enhancement for an offense involving a semiautomatic firearm with a large capacity magazine under § 2K2.1(a)(1) and a two-level enhancement for involvement in three or more firearms under § 2K2.1(b)(1)(A). The court’s decision rested on the standard that relevant conduct includes acts committed during the commission of the offense of conviction if they were part of a jointly undertaken criminal activity. Applying de novo review to legal conclusions and clear error review to factual findings, the court determined that Jackson and his associate Danez Beach engaged in a “jointly undertaken criminal activity” under U.S.S.G. § 1B1.3(a)(1)(B) on August 13, 2024. The court found that their coordinated travel to a 7-Eleven store to sell firearms to ATF agents, along with their mutual assistance and protection, established an implicit agreement sufficient to attribute Beach’s sale of a high-capacity magazine firearm to Jackson. The court rejected Jackson’s argument that his presence alone was insufficient, citing the coordinated nature of the enterprise and applying commentary from U.S.S.G. § 1B1.3 n.4(C)(viii) regarding joint criminal activity where participants provide mutual assistance. Because Beach’s firearm was part of Jackson’s relevant conduct, it satisfied the requirements for both the large-capacity magazine enhancement and the three-or-more-firearms enhancement. The practical consequence is that Jackson’s conviction and 60-month prison sentence, which included the disputed enhancements, remain in effect. The judgment is affirmed, and the case is closed with no further action required by the district court regarding these specific sentencing issues. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.