Whether a defendant's uncharged possession of firearms is 'relevant conduct' for sentencing enhancement

QUESTIONS PRESENTED This case presents unsettled and important questions related to the scope and application of “relevant conduct” to prove specific offense characteristics that dramatically increase a defendant’s sentencing exposure under the United States Sentencing Guidelines. Lonnie Ear] Parlor pled guilty to one count of unlawful possession of a firearm. The charge stemmed from his transfer of a rifle and a shotgun to a confidential informant. At sentencing, the district applied three specific offense characteristics, based on Parlor’s uncharged possession of different firearms at a different time and under different circumstances, which increased Parlor’s Guidelines range 57 to 71 months to an above statutory maximum of 121 to 151 months. The court sentenced him to 120 months. The questions presented are: 1. Whether a defendant’s uncharged possession of three firearms weeks after the charged offense and under different circumstances is “relevant conduct” such that his sentence can be enhanced for possessing more than two firearms under U.S.8.G. § 2K2.1(b)(1). 2. Whether a defendant’s uncharged possession of a revolver weeks after the charged offense and under different circumstances is “relevant conduct” that supports a four-level enhancement for possession of a firearm "in connection with another felony offense" — here, alleged drug trafficking — under U.S.S.G. § 2K2.1(b)(6)(B).