U.S.S.G. § 2K2.1(b)(6)(B) “In Connection With” Satisfied When the Firearm Is an Element of a Distinct Concealed-Carry Felony; Unpronounced Supervised-Release Conditions Must Be Vacated

1. Introduction

United States v. Jddarrian Irons addresses three recurrent federal sentencing questions in firearms cases: (1) whether a prior state conviction—here, Florida attempted carjacking—qualifies as a Guidelines “crime of violence” for purposes of the base offense level in U.S.S.G. § 2K2.1(a)(4)(A); (2) whether the “in connection with another felony offense” enhancement in U.S.S.G. § 2K2.1(b)(6)(B) applies when the “other felony” is a state concealed-carry offense whose elements include possessing the same firearm; and (3) whether discretionary supervised-release conditions appearing only in the written judgment (and not orally pronounced) must be vacated.

The parties were the United States (appellee) and Jddarrian Christopher Irons (appellant), who pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The relevant facts were simple and typical of street-level firearms prosecutions: police observed Irons, stopped a vehicle for a seatbelt violation, smelled marijuana, and found a handgun in a distinctive fanny pack associated with Irons.

The appeal turned not on guilt, but on how the Sentencing Guidelines and sentencing procedure applied to Irons’s prior Florida attempted carjacking conviction, his contemporaneous Florida concealed-carry offense, and the district court’s method of imposing supervised-release conditions.

2. Summary of the Opinion

The Eleventh Circuit:

• Affirmed the base offense level of 20 under U.S.S.G. § 2K2.1(a)(4)(A), holding the district court did not plainly err in treating Florida attempted carjacking as a “crime of violence,” particularly in light of U.S.S.G. § 4B1.2(d) (Nov. 2023) and circuit precedent recognizing that attempt offenses are included.
• Affirmed the four-level enhancement under U.S.S.G. § 2K2.1(b)(6)(B), holding that Irons’s Florida concealed-carry felony was “another” felony distinct from § 922(g)(1), and that Irons possessed the firearm “in connection with” that felony because the firearm was an element that made the concealed-carry offense possible.
• Vacated two discretionary supervised-release conditions—(i) obtaining a GED and (ii) submitting to computer searches— because the district court did not orally pronounce those conditions at sentencing, but included them for the first time in the written judgment.
• Remanded for resentencing limited to correcting the supervised-release conditions, leaving the prison term intact.

Judge Abudu concurred in affirming the base offense level and vacating the supervised-release conditions, but dissented as to the § 2K2.1(b)(6)(B) enhancement, arguing the firearm did not “facilitate” the concealed-carry offense because it “constituted it.”

3. Analysis

3.1. Precedents Cited and Their Role

A. Standards of review and error preservation

• United States v. Bishop, 940 F.3d 1242 (11th Cir. 2019): supplied the basic interpretive framework—Guidelines interpretation reviewed de novo; factual findings for clear error—and served as a reference point (both majority and dissent) for what “in connection with” means in § 2K2.1(b)(6)(B) litigation.
• United States v. Rodriguez, 75 F.4th 1231 (11th Cir. 2023): controlled the supervised-release issue by reiterating that discretionary conditions must be pronounced at the sentencing hearing and cannot be added later in the written judgment; also provided the de novo review standard where a defendant had no opportunity to object.
• United States v. Johnson, 694 F.3d 1192 (11th Cir. 2012): framed when plain-error review applies (opportunity to object but failure to do so).
• United States v. Hill, 119 F.4th 862 (11th Cir. 2024), United States v. Sanchez, 940 F.3d 526 (11th Cir. 2019), and United States v. Sammour, 816 F.3d 1328 (11th Cir. 2016): together supplied the “obviousness” requirement for plain error— error must be clearly established by explicit statutory language or on-point Supreme Court/Eleventh Circuit precedent, and holdings (not dicta) are required. This was decisive to rejecting Irons’s attempt to re-litigate which Guidelines manual should apply.

B. “Crime of violence,” Florida robbery/carjacking, and inchoate offenses

• Cruller v. State, 808 So. 2d 201 (Fla. 2002): described Florida carjacking as a subset of Florida robbery, supporting the inference that if Florida robbery involves sufficient force, Florida carjacking will too.
• Stokeling v. United States, 139 S. Ct. 544 (2019): held Florida robbery qualifies as a violent felony under the Armed Career Criminal Act; the panel treated this as strong analogical support that Florida carjacking (as a robbery subset) satisfies the “use, attempted use, or threatened use of physical force” concept used in the Guidelines’ force clause.
• United States v. Ochoa, 941 F.3d 1074 (11th Cir. 2019): authorized consulting Armed Career Criminal Act decisions for guidance when evaluating whether an offense is a “crime of violence” under the Guidelines.
• United States v. Ott, 166 F.4th 116 (11th Cir. 2026): supplied the key proposition that when the completed offense is a “crime of violence,” its attempt also qualifies (reinforced by the 2023 Guidelines text expressly including attempts). The panel also used Ott to rebut the claim that the 2023 movement of “attempt” language from commentary into text was necessarily “substantive.”
• United States v. Kapordelis, 569 F.3d 1291 (11th Cir. 2009): stated the ex post facto-related rule that the Guidelines in effect at the time of the offense must be used if the later Guidelines are harsher. The panel accepted the rule but found Irons could not show “obvious” prejudice under plain-error review because the relevant “attempt” language plausibly applied under both 2021 and 2023 versions (as clarifying).
• United States v. Horn, 129 F.4th 1275 (11th Cir. 2025) and United States v. Jerchower, 631 F.3d 1181 (11th Cir. 2011): underwrote the “clarifying vs. substantive” amendment analysis—moving explanatory commentary into guideline text can be clarifying and can evidence how the Commission intended the earlier guideline to operate.
• United States v. Dupree, 57 F.4th 1269 (11th Cir. 2023) (en banc), United States v. Taylor, 142 S. Ct. 2015 (2022), and United States v. Lightsey, 169 F.4th 1241 (11th Cir. 2026): invoked by Irons to argue the attempt language change was substantive; the panel distinguished them because they did not “specifically and directly” resolve the effect of this particular Guidelines amendment and because Taylor addressed a statute lacking the Guidelines’ attempt commentary/text structure.

C. § 2K2.1(b)(6)(B): “another felony offense” and “in connection with”

• United States v. Jackson, 276 F.3d 1231 (11th Cir. 2001): supported the notion that “another felony offense” may be distinct even when committed contemporaneously; the panel used it to reject the claim that overlap in time/episode negates distinctness.
• United States v. Walker, 771 F.3d 449 (8th Cir. 2014): persuasive authority for treating felon-in-possession and concealed-carry as distinct offenses and allowing § 2K2.1(b)(6)(B) where the defendant is not “doomed” to commit the concealment felony merely by possessing the gun.
• Rehaif v. United States, 139 S. Ct. 2191 (2019): provided the elements of § 922(g)(1) (knowing possession and knowledge of felony status), which the panel contrasted with Florida’s concealment element to show distinctness.
• Dorelus v. State, 747 So. 2d 368 (Fla. 1999): defined Florida concealment and explained its purpose (preventing undue advantage), reinforcing that concealment is an additional, distinct element beyond mere possession.
• United States v. Hall, 77 F.3d 398 (11th Cir. 1996), abrogated on other grounds by Johnson v. United States, 576 U.S. 591 (2015): cited to emphasize concealed-carry offenses’ heightened immediacy of violence relative to simple possession; used as contextual support for treating concealment as materially different conduct.
• United States v. Howard, 742 F.3d 1334 (11th Cir. 2014): supplied the federal “possession” concept (“ownership, dominion, or control”), used in contrasting possession with concealment.
• United States v. Brooks, 112 F.4th 937 (11th Cir. 2024) and United States v. James, 135 F.4th 1329 (11th Cir. 2025): formed the modern Eleventh Circuit articulation that “in connection with” is satisfied where the firearm facilitates or has the potential to facilitate the other felony, with “expansive” pathways (emboldening, availability to resist law enforcement, etc.). The panel relied on these cases to legitimate a facilitation theory not limited to drug trafficking or violent crimes.
• Smith v. United States, 508 U.S. 223 (1993): pivotal to the panel’s key move—if the other felony “would not have been possible” without the firearm, the firearm has the requisite role in that felony. The panel treated this as establishing that facilitation can be satisfied where the firearm is essential to the predicate felony’s commission.
• United States v. Young, 115 F.3d 834 (11th Cir. 1997): used to reject an argument that the enhancement requires the firearm to contribute to a crime in the “expected manner”; the text can cover unanticipated factual patterns.

D. Pronouncement of supervised-release conditions (oral vs written)

• United States v. Read, 118 F.4th 1317 (11th Cir. 2024): required vacatur and remand when discretionary conditions appear only in the written judgment.
• United States v. Zinn, 321 F.3d 1084 (11th Cir. 2003): provided ripeness principles; the panel used it to reject the government’s claim that Irons’s GED-condition challenge was premature.

3.2. Legal Reasoning

A. Base offense level: why plain-error doctrine did the work

Irons’s principal strategic problem was procedural: he did not object to the “crime of violence” base offense level at sentencing, so he faced plain-error review. Under Hill/Sanchez, he had to show an obvious legal error.

The panel did not need to definitively decide every underlying “crime of violence” question in the abstract; it was enough that existing authority made the district court’s approach at least reasonable and not clearly forbidden. The court emphasized:

• Florida carjacking’s relationship to Florida robbery (Cruller v. State), and Florida robbery’s treatment as a violent felony (Stokeling v. United States).
• The permissibility of using Armed Career Criminal Act cases as guidance (United States v. Ochoa).
• The Guidelines’ express inclusion of attempts in the operative manual (U.S.S.G. § 4B1.2(d) (Nov. 2023)), and United States v. Ott’s statement that “so does its attempt.”

Irons tried to reframe the issue as an ex post facto Guidelines problem (United States v. Kapordelis) by insisting the 2021 manual should govern. But the panel treated the 2023 “attempt” change as plausibly clarifying (via United States v. Horn and United States v. Jerchower), which undermined any claim that using the 2021 manual would “obviously” change the outcome—fatal under plain-error review.

B. The enhancement: two separate holdings—distinctness and facilitation

The § 2K2.1(b)(6)(B) enhancement turned on two textual predicates: (1) whether Florida concealed carry was “another felony offense,” and (2) whether Irons possessed the firearm “in connection with” it. The majority answered both in the government’s favor.

(1) “Another felony offense”: distinct elements, not distinct episodes

Relying on ordinary meaning (“different or distinct”), guideline commentary (U.S.S.G. § 2K2.1 cmt. 14(c) (Nov. 2023)), and United States v. Jackson, the court reasoned that contemporaneous commission does not collapse two crimes into one if they prohibit different conduct.

The comparison of elements did the heavy lifting:

• § 922(g)(1) requires knowing possession and knowledge of felony status (Rehaif v. United States).
• Florida concealed carry requires carrying a firearm “on or about” the person in a manner concealed from ordinary sight (Dorelus v. State).

That concealment element meant Irons was “not doomed” to commit the additional felony merely by being a felon in possession; he committed the Florida felony by taking an additional step—concealment. The panel also cited United States v. Walker to reinforce that other circuits treat a concealed-carry offense as distinct for § 2K2.1(b)(6)(B) purposes.

(2) “In connection with”: facilitation can be satisfied because the gun makes the other felony possible

The panel reiterated the general test from United States v. Brooks: facilitation or potential facilitation, with expansive ways to show it (emboldening, availability, etc.). But the panel adopted a notably direct application of Smith v. United States—a firearm facilitates the other felony where the felony “would not have been possible” without the firearm.

This reading treats “in connection with” as satisfied not only when the gun provides protection, leverage, intimidation, or emboldenment, but also when the gun is an “integral part” of committing the other felony (here, the concealed-carry violation).

C. Supervised release: the oral-pronouncement rule as a procedural safeguard

The supervised-release portion is straightforward and doctrinally firm in the Eleventh Circuit after United States v. Rodriguez and United States v. Read: discretionary conditions must be pronounced in open court. The written judgment cannot add them later.

Applying that rule, the panel vacated:

• The requirement that Irons “shall obtain his GED while on supervision” (the judge only said he “want[ed]” Irons to get it, and not as a pronounced condition).
• The requirement to submit to searches of Irons’s “computer” (the judge listed person/residence/business/storage/vehicle but never mentioned computers).

The panel rejected the government’s ripeness defense (United States v. Zinn) because the harm is procedural and immediate: Irons was subjected to conditions never imposed in his presence.

D. The dissent’s core objection (Judge Abudu)

Judge Abudu agreed on the base offense level and the supervised-release vacatur, but disputed the enhancement’s “facilitation” logic. The dissent framed the majority’s approach as circular: the firearm did not facilitate concealed carry; it “constituted it.” The dissent emphasized the line in Eleventh Circuit cases between mere overlap and a functional relationship, drawing support from United States v. Jackson, United States v. James, and the separate writings in United States v. Brooks.

Practically, the dissent warned that the enhancement risks converting a single act of unlawful possession into a second predicate without an “additive” role for the firearm—an interpretation the dissent considered inconsistent with the ordinary facilitation concept.

3.3. Impact

A. Sentencing exposure in firearm cases involving concealed carry

The most consequential aspect of the decision is its acceptance of a “made the felony possible” theory of facilitation under § 2K2.1(b)(6)(B) when the “other felony” is a firearm-possession-based offense (Florida carrying a concealed firearm). If applied broadly, this theory may:

• Increase guideline ranges in cases where defendants commit § 922(g)(1) and a state concealed-carry felony arising from the same firearm and same episode—because “another felony offense” can be distinct by elements, and “in connection with” can be satisfied by element-necessity.
• Encourage prosecutors to identify (and prove by a preponderance at sentencing) additional state firearm felonies—concealment, brandishing, or similar offenses—as enhancement predicates even when no separate criminal objective (drugs, burglary, assault) is present.

B. Continued tightening of the oral pronouncement requirement

On supervised release, the opinion reinforces a clear administrative rule with meaningful consequences: if a condition is discretionary, it must be said in open court. The remedy is not “harmless error”; it is vacatur and remand. This incentivizes:

• District courts to read (or incorporate with clarity) all discretionary conditions at sentencing.
• Defense counsel to compare oral pronouncements against written judgments and promptly appeal discrepancies.
• Probation and prosecutors to ensure the final written judgment matches what was actually imposed.

C. Guidelines amendments: clarifying vs. substantive as a recurring battleground

The panel’s discussion of the 2023 movement of inchoate-offense language from commentary to text, and its reliance on United States v. Horn/United States v. Jerchower, signals that defendants raising ex post facto-based Guidelines arguments will often face an uphill climb—especially on plain-error review—when the change can plausibly be labeled “clarifying.”

4. Complex Concepts Simplified

• “Crime of violence” (Guidelines): A defined term (via U.S.S.G. § 4B1.2) that, in relevant part, covers offenses that require the use, attempted use, or threatened use of physical force. If a prior conviction counts, it can increase a defendant’s base offense level for a firearms case.
• Plain error review: A demanding appellate standard used when the defendant did not object in the trial court. The defendant must show an obvious legal error, prejudice, and a serious effect on fairness/integrity of proceedings.
• “Clarifying” vs. “substantive” Guidelines changes: A clarifying amendment is treated as explaining what the Commission meant all along; a substantive amendment changes the meaning. This matters for which manual applies and whether later text can inform earlier interpretation.
• § 2K2.1(b)(6)(B) “in connection with”: Typically means the gun helped (or could have helped) the other felony—e.g., by protection, emboldening, or leverage. Here, the majority also accepted a more direct route: the gun “facilitates” if it is necessary to commit the other felony at all.
• Oral pronouncement of supervised-release conditions: Discretionary conditions must be stated at the sentencing hearing so the defendant can hear them, consult counsel, and object. A written judgment cannot add new conditions later.
• Ripeness: Courts avoid deciding abstract disputes too early. But a challenge to unpronounced supervised-release conditions is ripe immediately because the problem is the defective imposition itself.

5. Conclusion

United States v. Jddarrian Irons delivers two clear rules with practical consequences. First, it reinforces that unpronounced discretionary supervised-release conditions—added only in a written judgment—must be vacated and remanded under United States v. Rodriguez and United States v. Read. Second, it approves applying U.S.S.G. § 2K2.1(b)(6)(B) where the “other felony” is a distinct state concealed-carry offense and the firearm “facilitates” that offense in the sense that it makes the offense possible because it is an element of the crime.

The dissent highlights a live interpretive fault line: whether “facilitation” should require an “additive” functional role beyond the firearm’s being the object/element of the other offense. That debate is likely to shape future Eleventh Circuit (and potentially Supreme Court) attention to the outer boundaries of § 2K2.1(b)(6)(B) in firearm-on-firearm predicate scenarios.