Establishing “Connection” and “Recklessness” in Firearm Sentencing Enhancements: United States v. Pringle

Introduction

United States v. Robert Lee Pringle (11th Cir. Apr. 15, 2025) addresses two important enhancements under the United States Sentencing Guidelines: the four-level increase for possessing a firearm “in connection with another felony offense” (U.S.S.G. § 2K2.1(b)(6)(B)), and the two-level increase for recklessly creating a substantial risk of death or serious bodily injury during flight from law enforcement (U.S.S.G. § 3C1.2).

Background: Pringle, a convicted felon, pleaded guilty to possession of a firearm in violation of 18 U.S.C. § 922(g)(1). During a police stop of a stolen vehicle he was driving, he fled at high speed, crashed into another car, and was later found in possession of two handguns, ammunition, and drug contraband. The probation officer recommended enhancements under §§ 2K2.1(b)(6)(B) and 3C1.2, yielding a total offense level of 25, criminal history category VI, and a guideline range of 110–120 months (statutory max 120). The district court imposed a 120-month sentence. Pringle appealed both enhancements and the substantive reasonableness of his sentence. The Eleventh Circuit affirmed.

Summary of the Judgment

Enhancement under § 3C1.2 (Reckless Flight): The court held that Pringle’s high-speed flight and subsequent crash in a populated intersection created a substantial risk of death or serious bodily injury, justifying a two-level increase. Flight alone is insufficient, but reckless speeding in an environment where third parties are present meets the standard (citing United States v. Washington, 434 F.3d 1265 (11th Cir. 2006)).
Enhancement under § 2K2.1(b)(6)(B) (Firearm Connected to Another Felony): The court found no clear error in concluding that Pringle “possessed” the firearms in connection with his felony drug possession and grand theft of a motor vehicle. The proximity of loaded weapons to drugs and paraphernalia, coupled with the presumption that a defendant aware of a firearm will use it to protect illegal activity, supported the four-level increase (citing United States v. Brooks, 112 F.4th 937 (11th Cir. 2024)).
Substantive Reasonableness: Reviewing for abuse of discretion, the court held that a within-guidelines sentence of 120 months did not reflect a clear error of judgment. The district court properly weighed the § 3553(a) factors, emphasizing Pringle’s extensive criminal history, the seriousness of combining firearms with drug activity and flight, and the need for deterrence and public protection.

Analysis

Precedents Cited

United States v. Washington (434 F.3d 1265): Established that simple flight does not trigger § 3C1.2, but reckless high-speed flight in areas with potential for civilian presence does.
United States v. Matchett (802 F.3d 1185): Clarified the standards for reviewing factual findings (clear error) and legal applications (de novo).
United States v. Cook (181 F.3d 1232): Emphasized that conduct giving rise to an enhancement must be the defendant’s own reckless act—not merely a co-conspirator’s.
United States v. Brooks (112 F.4th 937): Held that a firearm “in connection with” another felony offense need only facilitate, or have the potential to facilitate, the offense; proximity to contraband and the loaded condition of the weapon support the presumption of potential facilitation.
United States v. Bishop (940 F.3d 1242): Warned that mere proximity of personal-use drug possession to a firearm is insufficient absent a finding of facilitation potential—but was distinguished here by the quantity of drugs and context.
Oudomsine, Rosales-Bruno, Irey: Provided guidance on the standard of review for sentencing enhancements and overall sentence reasonableness under 18 U.S.C. § 3553(a).

Legal Reasoning

On § 3C1.2, the court found no clear error in the district court’s factual determination that Pringle’s flight “recklessly created a substantial risk of death or serious bodily injury.” Although the officer lost sight before the crash, the subsequent high-speed collision at a busy intersection placed bystanders in danger. The court reiterated that actual injury is not required—risk alone suffices.

On § 2K2.1(b)(6)(B), the Eleventh Circuit accepted two alternative rationales: (1) under Application Note 14(B), the close proximity of two firearms (one loaded) to drugs and paraphernalia demonstrates potential to facilitate Pringle’s drug distribution or defense of his stolen vehicle; (2) under Note 14(A), the weapons facilitated or could facilitate separate felonies (drug possession and grand theft of a motor vehicle). The court rejected Pringle’s reliance on Bishop by distinguishing personal-use scenarios from those involving distribution quantities and stolen property.

On substantive reasonableness, the district court’s within-guidelines sentence fell squarely within the presumptively reasonable range. The court considered Pringle’s traumatic childhood and health issues but gave greater weight to his lengthy criminal record, possession of firearms during another felony, and reckless endangerment. The Eleventh Circuit affirmed that such a balancing decision does not constitute an abuse of discretion.

Impact

United States v. Pringle reinforces that:

Reckless flight at high speed—even if no one is injured—can trigger the § 3C1.2 enhancement when the defendant’s conduct places others at substantial risk.
A firearm need not be actively employed in another felony to merit the § 2K2.1(b)(6)(B) increase; potential facilitation, especially where contraband and weapons are co-located, suffices.

Future courts in the Eleventh Circuit will rely on Pringle to justify enhancements in similar fact patterns, limiting arguments that mere presence of a weapon is de minimis when felony conduct is ongoing.

Complex Concepts Simplified

Clear Error vs. De Novo Review: Clear error: appellate courts defer to the district court’s factual findings unless they are “clearly wrong.”
De novo: appellate courts review legal questions from scratch, without deference.
“In Connection With” a Felony: The legal test asks whether the firearm “facilitates or has the potential to facilitate” another felony. A defendant aware of an accessible, loaded weapon is presumed to consider its use to protect or advance criminal activity.
Reckless Endangerment Enhancement (§ 3C1.2): This two-level bump applies if a defendant’s reckless conduct during flight from law enforcement creates a substantial risk of serious injury or death to others—even if no one is actually hurt.

Conclusion

United States v. Pringle clarifies two key sentencing-guideline enhancements. First, reckless high-speed flight that endangers bystanders triggers § 3C1.2. Second, firearms co-located with drugs or stolen property support a § 2K2.1(b)(6)(B) increase based on potential facilitation of additional felonies. The decision underscores the Eleventh Circuit’s willingness to uphold within-guidelines sentences where a defendant’s conduct presents real risks to public safety and where weapons are intertwined with other criminal acts.