United States v. Greeno

Investigating a methamphetamine trafficking conspiracy, officers conducted two controlled purchases of methamphetamine at defendant’s property. Within three days, they executed a search warrant on the property, which contained a house, a recreational vehicle, and a garage. They found a revolver between the bed and wall of the RV, near drug paraphernalia, including electrical tape similar to that used on methamphetamine in controlled purchases. A handgun was found in the garage laundry room; an unloaded rifle and ammunition were in a tool room. Near the garage, officers found a canister of methamphetamine buried in the ground. A smaller package of methamphetamine was wrapped in electrical tape outside the RV. Defendant pled guilty to conspiracy to distribute at least 50 grams of methamphetamine or at least five hundred grams of a substance containing methamphetamine, 21 U.S.C. 841(a) and (b)(1)(A). The district court applied a two-level enhancement for possession of a dangerous weapon during a drug offense, U.S.S.G. 2D1.1(b)(1), increasing the advisory range from 70 to 87 months to 87 to 108 months in prison, and sentenced him to 87 months. The Sixth Circuit affirmed, rejecting an argument that the enhancement violated defendant's Second Amendment right to keep and bear arms.