District Courts Must Identify and Explain the Predicate Felony for U.S.S.G. § 2K2.1(b)(6)(B) Enhancements; Conceded Suppression Grounds Are Waived on Appeal

Case: United States v. Quillan Inman (4th Cir. June 5, 2026) (unpublished)
Disposition: Conviction affirmed; sentence vacated; remanded for resentencing
Key holdings: (1) A defendant who conceded the lawfulness of a traffic stop in the district court waives a later appellate challenge to the stop; (2) when applying U.S.S.G. § 2K2.1(b)(6)(B), the district court must identify the predicate felony offense and explain the “in connection with” nexus—mere recitation of guideline language is insufficient.

1. Introduction

In United States v. Quillan Inman, the Fourth Circuit addressed two recurring criminal-procedure and sentencing issues: (1) whether a defendant may challenge the legality of a traffic stop on appeal after conceding in the district court that the stop was lawful; and (2) what findings are required to support the four-level enhancement for possessing a firearm “in connection with another felony offense” under U.S.S.G. § 2K2.1(b)(6)(B).

The case arose from a Robeson County, North Carolina traffic stop that escalated into a vehicle pursuit. After the vehicle was stopped and the driver fled, officers approached passenger Quillan Inman, observed firearms, detained him, and discovered cash and suspected controlled substances on his person. A jury convicted Inman of one count of being a felon in possession of a firearm under 18 U.S.C. §§ 922(g)(1) and 924. At sentencing, the district court applied § 2K2.1(b)(6)(B), increasing the Guidelines range substantially.

On appeal, Inman attacked both (a) the admission of evidence stemming from the stop and (b) the sentencing enhancement. The Fourth Circuit found the suppression argument waived, but vacated the sentence because the district court did not make the predicate-felony and nexus findings necessary to apply the enhancement.

2. Summary of the Opinion

  • Suppression / conviction: The Fourth Circuit held Inman waived any appellate argument that the traffic stop was unlawful because, in his suppression motion, he expressly conceded the stop was justified by a traffic infraction. Waived arguments are not reviewable, “even for plain error.” The conviction was therefore affirmed.
  • Sentencing: The Fourth Circuit held the district court committed procedural error by applying U.S.S.G. § 2K2.1(b)(6)(B) without identifying the “other felony offense” or making/findings adopting facts establishing the predicate felony and the required “in connection with” relationship. Because the error was not harmless (the sentence exceeded the unenhanced range), the sentence was vacated and the case remanded.

3. Analysis

3.1. Precedents Cited (and How They Shape the Decision)

A. Waiver vs. forfeiture and the suppression issue

  • United States v. Olano, 507 U.S. 725 (1993): The opinion anchors the waiver doctrine in Olano’s definition—waiver is the “intentional relinquishment or abandonment of a known right.” The Fourth Circuit uses this framework to treat Inman’s district-court concession as an intentional abandonment, not a mere omission.
  • United States v. Robinson, 744 F.3d 293 (4th Cir. 2014) (citing Kontrick v. Ryan, 540 U.S. 443 (2004)): Robinson supplies the critical appellate consequence: waived arguments are unreviewable “even for plain error,” unlike forfeited arguments. Kontrick is invoked for the definitional distinction between waiver and forfeiture.
  • United States v. Boyd, 5 F.4th 550 (4th Cir. 2021): The panel relies on Boyd for the proposition that waiver occurs when an argument is “expressly and clearly deserted,” and that a concession can “demonstrate[] a clear abandonment” of the later-asserted theory.
  • United States v. Claridy, 601 F.3d 276 (4th Cir. 2010): Claridy provides a close analogy: the Fourth Circuit declined to review a suppression claim where the defendant had admitted a key premise (probable cause) below. Inman uses this to reinforce that a defendant cannot concede a dispositive point in the district court and revive it on appeal.

Doctrinal significance: Inman is a practical application of established waiver law in the suppression context: an explicit concession regarding the legality of a stop locks in the issue and forecloses appellate review, even if the defendant later reframes the suppression theory.

B. Sentencing findings, individualized explanation, and § 2K2.1(b)(6)(B)

  • United States v. Evans, 90 F.4th 257 (4th Cir. 2024): Establishes that misapplication of a Guidelines enhancement is “significant procedural error” requiring vacatur absent harmlessness.
  • United States v. Cisson, 33 F.4th 185 (4th Cir. 2022) (citing United States v. Allen, 446 F.3d 522 (4th Cir. 2006)): Supplies the standard of review (legal conclusions de novo; factual findings for clear error) and frames the substantive § 2K2.1(b)(6)(B) inquiry (possession “in connection with” another felony). It also provides the harmless-error framework the court applies after finding procedural error.
  • United States v. Green, 436 F.3d 449 (4th Cir. 2006) (citing 18 U.S.C. § 3553(c)): Supports the obligation that the district court “must make factual findings, as appropriate or necessary” to carry out sentencing.
  • United States v. Carter, 564 F.3d 325 (4th Cir. 2009): A central driver of the vacatur: the appellate court will not presume the district court “silently adopted” a party’s arguments, and it will not “guess” at rationale by rummaging through the record for “clues.”
  • Gall v. United States, 552 U.S. 38 (2007): Reinforces the need for an “individualized assessment based on the facts presented,” which here demanded explicit identification of the predicate felony and the nexus findings for the enhancement.
  • United States v. Jenkins, 566 F.3d 160 (4th Cir. 2009): Provides the core “in connection with” test: the firearm must “facilitate[], or ha[ve] the potential of facilitating” another felony. It also emphasizes that “accident or coincidence” is not enough.
  • United States v. Blount, 337 F.3d 404 (4th Cir. 2003): Cited through Jenkins for the “accident or coincidence” limitation—proximity alone does not automatically satisfy the enhancement.
  • United States v. Bolden, 964 F.3d 283 (4th Cir. 2020): Used as a caution against appellate “assumptions” about predicate felonies—where the predicate is not “so obvious from the record” that the appellate court can confidently supply what the district court did not.
  • United States v. Williams, 152 F.3d 294 (4th Cir. 1998): Establishes that when facts are contested, the district court must resolve them by making findings or expressly adopting PSR findings. Inman’s district court did neither.
  • United States v. Mills, 917 F.3d 324 (4th Cir. 2019): Provides the articulation (quoted in Cisson) of the harmlessness inquiry: whether the district court would have reached the same result absent the error.

C. Guidelines-manual timing

  • United States v. Lewis, 606 F.3d 193 (4th Cir. 2010) and U.S.S.G. § 1B1.11(a): Cited to explain that the sentencing court uses the Guidelines Manual in effect at sentencing, relevant here because Amendment 834 redesignated § 2K2.1(b)(6)(B) as § 2K2.1(b)(7)(B) effective November 1, 2025.

3.2. Legal Reasoning

A. The suppression issue turned on waiver, not Fourth Amendment merits

Although Inman attempted on appeal to contest the lawfulness of the stop itself, the panel focused on what he did in the district court: he affirmatively stated that the “traffic infraction justified stopping the car,” while challenging only the scope of the ensuing search. That express concession fit the Fourth Circuit’s waiver template (as drawn from Olano, Robinson, and Boyd), so the appellate court treated the stop’s legality as a waived issue and refused to review it at all.

The upshot is that the appellate court never reached questions such as whether the alleged lane violation was adequately supported, whether the stop was pretextual, or whether the pursuit altered the analysis—because waiver foreclosed those merits questions.

B. The sentencing issue: § 2K2.1(b)(6)(B) requires a specified predicate felony and an explained nexus

The panel identified the enhancement’s essential structure: (1) an “other felony offense” must exist, and (2) the firearm must have facilitated or had the potential to facilitate that felony. The Government bears the burden by a preponderance of the evidence.

Here, the district court said only that Inman possessed the firearm “in connection with another felony offense,” without naming the felony (e.g., drug trafficking, felony possession, or some other offense) and without making factual findings supporting any specific felony theory. Compounding the problem, the district court also did not adopt the PSR’s factual findings about the suspected drugs and medications, nor did it resolve the contested facts itself—contrary to Williams.

Under Carter, the Fourth Circuit refused to presume the district court silently accepted either party’s narrative or legal theory. And under Bolden, it refused to “assume the district court’s fact-finding role” because no predicate felony was “so obvious from the record” that the appellate court could fill in the blanks. That absence of findings rendered the enhancement procedurally erroneous.

C. Harmless-error analysis failed

Applying Cisson’s two-part harmlessness inquiry, the panel found the error not harmless because: (1) it was not clear the district court would have imposed the same sentence without the enhancement, and (2) the imposed 100-month sentence exceeded the unenhanced range’s ceiling (63–78 months), making it difficult to conclude the same sentence would be reasonable and independently selected absent the error.

3.3. Impact

A. Sentencing practice in firearm cases (especially drug-adjacent stops)

The most immediate impact is on district-court sentencing procedure when § 2K2.1(b)(6)(B) is in play. Inman reinforces that courts must do more than invoke the guideline’s phraseology: they must identify the specific predicate felony and articulate the factual basis and nexus showing facilitation or potential facilitation.

Practically, this decision incentivizes clearer records at sentencing:

  • For the Government: present a clearly delineated predicate felony theory (and its elements), tie the evidence to that theory, and request explicit findings.
  • For defendants: force the issue by contesting the predicate felony and nexus, and object to any failure to adopt PSR facts or make independent findings.
  • For district courts: expressly adopt PSR paragraphs (when reliable and undisputed) or make detailed findings when facts are disputed, then explain why the firearm facilitated (or could facilitate) the specific felony.

B. Appellate strategy and suppression litigation

On the suppression side, the decision underscores a strategic hazard: a defendant who concedes the stop’s legality to narrow the suppression dispute may unintentionally foreclose a potentially stronger appellate argument. Inman signals that the Fourth Circuit will treat such concessions as true waiver—not a mere failure to argue—thereby eliminating appellate review.

C. Persuasive (not binding) authority but likely influential

Because the opinion is unpublished, it is “not binding precedent in this circuit.” Nonetheless, the reasoning is tightly linked to binding cases (Olano, Carter, Gall, Jenkins), making it a useful roadmap for litigants and district courts confronting similar enhancement and waiver issues.

4. Complex Concepts Simplified

  • Waiver vs. forfeiture: Waiver is an intentional giving up of an argument (e.g., conceding the stop was lawful). A waived issue cannot be reviewed on appeal. Forfeiture is an accidental failure to raise an argument in time; forfeited issues may sometimes be reviewed for “plain error.”
  • Suppression: Excluding evidence obtained in violation of the Fourth Amendment (or related rules). If a stop or search is unlawful, evidence derived from it may be excluded—unless the argument is waived.
  • U.S.S.G. § 2K2.1(b)(6)(B) “in connection with” enhancement: A four-level increase when a firearm is used or possessed to help (or potentially help) another felony. Mere proximity is not automatically enough; the firearm must have a real relationship to the other felony.
  • Predicate felony offense: The “other felony offense” that the firearm supposedly facilitated. The court must specify what felony it is (e.g., drug trafficking) and why the facts support it.
  • Preponderance of the evidence: The sentencing burden of proof for enhancements—more likely than not.
  • Harmless error (sentencing): Even if the district court made a Guidelines mistake, the sentence stands only if the appellate court is convinced the same sentence would have been imposed anyway and would still be reasonable.

5. Conclusion

United States v. Quillan Inman delivers two clear procedural lessons. First, suppression litigation choices matter: explicitly conceding the lawfulness of a stop constitutes waiver and bars an appellate reversal theory premised on the stop’s illegality. Second, § 2K2.1(b)(6)(B) cannot be applied by incantation; the sentencing court must identify the specific predicate felony and explain—based on adopted or independently found facts—how the firearm facilitated or could facilitate that felony.

The case thus strengthens the Fourth Circuit’s insistence on transparent sentencing records and individualized explanations, while reinforcing strict waiver doctrine as a limit on appellate review.