Sunday, December 8, 2013

Vaughn v. Lawrenceburg Power System case brief

Vaughn v. Lawrenceburg Power System case brief summary
293 F.3d 703 (2001)


CASE SYNOPSIS
Defendant was convicted of possession of a firearm in furtherance of a drug trafficking crime under 18 U.S.C.S. § 924(c), in United States District Court for the Eastern District of Virginia, at Richmond. Defendant appealed, contending that there was insufficient evidence to convict him.

CASE FACTS
On review, the court found that there was more than sufficient evidence presented at the bench trial to support the district court's finding that defendant possessed a firearm in furtherance of a drug trafficking crime. Defendant had 19 hits of crack on his person, and he had not challenged his conviction for possession with the intent to distribute.

DISCUSSION

  • In finding a nexus between the drug trafficking activity and defendant's simultaneous possession of a semiautomatic pistol, the district court stressed that defendant would not be waving a heavy duty nine millimeter firearm unless it was for the purpose of protecting something of value, and the only thing of value defendant had on him was the crack. 
  • Furthermore, defendant's weapon was fully loaded and immediately accessible to him as he ran down the street holding it. 
  • Moreover, the gun was discovered at night under circumstances indicating that defendant was involved in drug trafficking. 
  • The police found him with individually packaged hits of crack, and he had called 911 in a cocaine-induced paranoia.
CONCLUSION
Defendant's conviction was affirmed.

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