United States v. Bryan Austin

A jury convicted Bryan Austin on three counts — possession with intent to distribute cocaine in violation of 21 U.S.C. § 841(a)(1), being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1), and possessing a firearm in furtherance of a drug trafficking crime in violation of 18 U.S.C. § 924(c)(1)(A). It did not return a verdict on another count. Austin appeals, arguing that the district court erred by addressing the jury outside his presence, and that there was insufficient evidence that he possessed the firearm in furtherance of a drug trafficking crime. 1 Having…