Affirmation of Sentencing Enhancements for Multiple Firearms and Felony-Related Firearm Use under U.S.S.G. §2K2.1

Introduction

United States v. Terrence Terrial Izear Turner is a 2025 Sixth Circuit decision reviewing a 165-month sentence imposed on Turner after he pled guilty to being a felon in possession of a firearm (18 U.S.C. §§ 922(g)(1), 924(a)(8)). The district court applied three separate Guidelines enhancements under U.S.S.G. § 2K2.1:

(b)(1)(A) for possession of three or more firearms;
(b)(4)(A) for possession of a stolen firearm; and
(b)(6)(B) for use or possession of a firearm in connection with another felony.

Turner appealed, challenging both the procedural application of those enhancements and the substantive reasonableness of his within-Guidelines sentence. The Sixth Circuit affirmed, emphasizing deference to the district court’s fact-finding on firearm possession and the broad discretion afforded to sentencing courts under Gall v. United States, 552 U.S. 38 (2007).

Summary of the Judgment

The Sixth Circuit held that the district court did not abuse its discretion either procedurally or substantively. On procedural review, the panel found “ample evidence” by a preponderance standard that Turner possessed four distinct firearms (a Glock 19X, a Glock 10 mm, a Taurus Spectrum .380, and a stolen Taurus PT111 G2) and that one of those was used in the July 9, 2023 shooting in Benton Harbor, Michigan. On substantive review, the court noted that Turner’s 165-month sentence fell within the advisory Guidelines range and was therefore “presumptively reasonable.” Because Turner failed to show that the district court overstated any sentencing factor or overlooked his mitigation, the sentence stood.

Analysis

Precedents Cited

Gall v. United States, 552 U.S. 38 (2007) – Establishes the abuse-of-discretion standard for reviewing both procedural and substantive reasonableness of a sentence.
United States v. Johnson, 79 F.4th 684 (6th Cir. 2023) – Clarifies that procedural abuses include significant errors like miscalculation of the Guidelines.
United States v. Rayyan, 885 F.3d 436 (6th Cir. 2018) – Confirms that challenges to sentence length are reviewed under a highly deferential abuse-of-discretion standard.
United States v. Seymour, 739 F.3d 923 (6th Cir. 2014) – Holds that factual findings about firearm use in connection with other felonies are reviewed for clear error.
United States v. Shanklin, 924 F.3d 905 (6th Cir. 2019) – Emphasizes that fact-specific determinations regarding firearm possession are “better examined by the district court.”
United States v. Barnes, No. 23-1974, 2024 WL 4298918 (6th Cir. Sept. 26, 2024) – Affirms deference to district court fact-finding where the defendant’s own admissions and social-media evidence support possession.

Legal Reasoning

The Sixth Circuit’s decision rests on three pillars:

Deference to District Court Fact-Finding: Turner’s challenges to each enhancement turned on whether the district court reasonably found, by a preponderance of the evidence, that he possessed multiple firearms, that one was stolen, and that he used one in the July 9 shooting. Under the clear-error standard, the Sixth Circuit credited the court’s assessment of eyewitness testimony, phone-call recordings, Facebook messages, photos, recovered shell casings, and Turner’s own admissions.
Abuse-of-Discretion Standard for Procedural Reasonableness: Citing Gall and Johnson, the panel explained that procedural reasonableness requires correct calculation of the Guidelines and meaningful consideration of any objections. Here, the district court heard and overruled Turner’s objections, explained its rationale for each enhancement, and did not commit any significant procedural error.
Presumption of Reasonableness for Within-Guidelines Sentences: Drawing on Vonner, the court noted that a sentence within the advisory range is presumptively reasonable. Turner offered no compelling argument that the district court gave undue weight to improper factors or ignored his mitigating circumstances. Consequently, the sentence was substantively reasonable.

Impact

United States v. Turner reinforces two important sentencing principles in the Sixth Circuit:

Heavy Deference to Trial Courts on mixed-fact issues (e.g., how many firearms a defendant possessed and whether those firearms were used in another felony).
Presumptive Validity of Within-Guidelines Sentences when a district court has followed the procedural requirements of 18 U.S.C. § 3553(a) and properly calculated the Guidelines.

Future defendants facing challenges to multi-firearm enhancements under U.S.S.G. § 2K2.1(b) will find it difficult to overturn a district court’s findings absent clear error or procedural missteps.

Complex Concepts Simplified

Abuse-of-Discretion Review: An appellate court will only overturn a ruling if it is arbitrary, unreasonable, or based on an error of law or fact.
Clear-Error Review: When a district court makes factual findings (e.g., whether a defendant possessed a certain gun), an appellate court will uphold those findings unless it is “left with the definite and firm conviction that a mistake has been committed.”
Preponderance of the Evidence: A standard of proof requiring that a fact is more likely true than not (i.e., greater than 50% probability).
Presumptively Reasonable: A within-Guidelines sentence is presumed appropriate, shifting the burden to the defendant to show it is unreasonable.

Conclusion

United States v. Turner stands as a robust affirmation of district court authority and discretion in sentencing. By upholding the three enhancements under U.S.S.G. § 2K2.1—possession of three or more firearms, possession of a stolen firearm, and use of a firearm in connection with another felony—the Sixth Circuit underscores the high bar for upsetting fact-based findings on appeal. Moreover, the decision reiterates that within-Guidelines sentences, once procedurally and substantively sound, enjoy a strong presumption of reasonableness. This precedent will guide future courts and practitioners in firearm sentencing litigation across the Circuit.