Does mere possession of a firearm, even during a brief physical struggle with law enforcement, support a § 3C1.2 enhancement?

QUESTION PRESENTED FOR REVIEW United States Sentencing Guidelines (“U.S.S.G.”) § 3C1.2 provides that the district court may apply a two-level enhancement “[i]f the defendant recklessly created a substantial risk of death or serious bodily injury to another person in the course of fleeing from a law enforcement officer[.]” US.S.G. § 3C1.2. Tigran Zmrukhtyan received a § 3C1.2 enhancement, where he engaged in a brief physical struggle with law enforcement while they were trying to arrest him. Zmrukhtyan had a firearm in his waistband, but did not use, brandish, display, or reach for the firearm during his brief resistance of arrest. The officers did not know Zmrukhtyan had the firearm until after he was arrested and searched. The question presented is: Does mere possession of a firearm, even during a brief physical struggle with law enforcement, support a § 3C1.2 enhancement? Statement of