DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
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.