Michael A. Watson v. United States

Subject:

18 U.S.C. § 924(c)(l)(A), Criminal Law & Procedure, Firearm Use, Sentencing

18 U.S.C. § 924(c)(l)(A) criminalizes the "use" of a firearm during and in relation to a drug trafficking offense and imposes a mandatory consecutive sentence of at least five years' imprisonment. In Bailey v. United States, 516 U.S. 137 (1995), this Court held that "use" of a firearm under § 924(c) means "active employment." Id. at 144. The question presented in this case is:


• Whether mere receipt of an unloaded firearm as payment for drugs constitutes "use" of the firearm during and in relation to a drug trafficking offense within the meaning of 18 U.S.C. § 924(c)(l)(A) and this Court's decision in Bailey.

Resources:

• Docket Sheet From the U.S. Supreme Court.