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223564P.pdf   01/30/2024  United States  v.  Henry Watkins, Jr.
   U.S. Court of Appeals Case No:  22-3564
   U.S. District Court for the Eastern District of Arkansas - Central   
[PUBLISHED] [Shepherd, Author, with Kelly and Stras, Circuit Judges] Criminal case - Criminal law and Sentencing. The evidence was sufficient to support defendant's conviction for being a felon in possession of a firearm; the district court did not err in applying an enhancement under Guidelines Sec. 2K2.1(b)(6) based on its finding that possession of the firearm facilitated defendant's drug possession; the district court did not err in increasing defendant's base offense level under Guidelines Sec. 2K2.1(a)(2) from 20 to 24 based on his prior Arkansas controlled-substance conviction; the district court plainly erred in presuming the guidelines range was reasonable and in adopting a sentence without considering the 3553(a) factors; these procedural errors, coupled with the fact that the court had previously granted defendant a 60-month downward variance, demonstrate a reasonable probability that defendant would have received a lighter sentence but for the errors; defendant's conviction is affirmed, but his sentence is vacated, and the matter is remanded for resentencing consistent with this opinion.