United States v. Inman

Background Quillan Inman was convicted of being a felon in possession of a firearm following a traffic stop and subsequent search that yielded firearms and controlled substances. The district court sentenced him to one hundred months of imprisonment, applying a four-point enhancement for possession of a firearm in connection with another felony offense. The court’s reasoning The court concluded that Inman waived his challenge to the traffic stop because he explicitly conceded its lawfulness before the district court. Regarding the sentence, the court found that the district court erred by applying the enhancement under Section two K two point one subsection b subsection six subsection B of the United States Sentencing Guidelines without making the requisite factual findings to identify a predicate felony offense. The court determined this error was not harmless because the sentence imposed exceeded the Guidelines range that would have applied absent the enhancement. What it means going forward The defendant’s conviction stands, but the sentence is vacated, requiring the district court to conduct a new sentencing hearing with proper factual findings regarding any predicate felony offense.