UNITED STATES v. WATSON (2020)

[Unpublished]

Kamaury Taujheim Watson pled guilty to possessing a firearm in violation of 18 U.S.C. § 922(g)(1) and (9), subject to penalties outlined in 18 U.S.C. § 924(a)(2). The district court ¹ sentenced him to 45 months of imprisonment, followed by 3 years of supervised release. Watson challenges his sentence. According to Watson, the district court misapplied § 2K2.1(b)(6)(B) of the United States Sentencing Guidelines Manual (“Guidelines”), resulting in an improper sentencing enhancement.

We disagree. Section 2K2.1(b)(6)(B) of the Guidelines increases a defendant’s offense level by four points if he “used or possessed any firearm or ammunition in connection with another felony offense.” U.S.S.G. § 2K2.1(b)(6)(B). And Watson possessed a gun “in connection with” a contemporaneous violation of Iowa Code section 724.4(1). Under United States v. Walker, violating Iowa Code section 724.4(1) counts as “another felony offense” for purposes of § 2K2.1(b)(6)(B). 771 F.3d 449, 452–53 (8th Cir. 2014).

Watson contends Walker was wrongly decided. However, Walker is binding precedent and one panel of this court cannot overrule a prior panel. Mader v. United States, 654 F.3d 794, 800 (8th Cir. 2011) (en banc). We therefore affirm his sentence.

FOOTNOTES

1.   The Honorable Stephanie M. Rose, United States District Judge for the Southern District of Iowa.

PER CURIAM.