Whether Kisor's limits on courts' deference to an agency's interpretation of its own regulation permitted deference to Comment 14(B), which expands the application of § 2K2.1(b)(6)(B)

QUESTION PRESENTED FOR REVIEW The U.S. Sentencing Commission issues Guidelines that yield a recommended sentence for criminal defendants. The Commission also issues Commentary, to assist in the interpretation of the Guidelines. This Court has held that the Commentary is like “an agency’s interpretation of its own legislative rules.” Stinson v. United States, 408 U.S. 36, 44 (1993). This Court recently cabined the deference courts should afford to agencies’ interpretations of their own rules: permitting deference only when the rule is genuinely ambiguous, the interpretation is within the zone of ambiguity, and the interpretation reflects the agency’s substantive expertise. Kisor v. Wilkie, 139 S. Ct. 2400, 2415-17 (2019). Michael Choulat is a felon who possessed a firearm along with methamphetamine and marijuana. U.S.S.G. § 2K2.1(b)(6)(B) mandated an enhanced sentence if his firearm was possessed “in connection with another felony offense.” Comment 14(B) created an irrebuttable presumption that, because the firearm was close to drug trafficking, they were connected. The question presented: Whether Kisor’s limits on courts’ deference to an agency’s interpretation of its own regulation permitted deference to Comment 14(B), which expands the application of § 2K2.1(b)(6)(B). i