United States v. Conrad Albert Krouse, III

For the first time in this circuit, we must decide what it means to possess a firearm “in furtherance of’ a drug trafficking offense under 18 U.S.C. § 924 (c)(1)(A). In so doing, we affirm the conviction and 161-month sentence of Conrad Albert Krouse. We conclude that sufficient evidence supports Krouse’s conviction for possession of a firearm “in furtherance” of a drug trafficking crime under § 924(c) because the facts in evidence demonstrate a sufficient nexus between the weapons discovered in Krouse’s home and his drug trafficking operation.

I

This case began with an investigation into the disappearance of various arcade and vending machines from a tavern in Buena Park, California. Suspecting that Krouse had stolen the machines, local police officers executed a search warrant on his home. They discovered the missing machines plus five firearms, ammunition, 86.5 grams of cocaine, and almost 150 pounds of marijuana.

Krouse was ultimately indicted on five federal weapons and drug charges, including one count of possession of firearms in furtherance of a drug trafficking offense. See 18 U.S.C. § 924 (c). At trial, Krouse claimed that the drugs and weapons discovered in his home…