United States v. Tyrone Parrow

Tyrone Parrow pled guilty to possessing a firearm after a domestic-abuse conviction, in violation of 18 U.S.C. § 922(g)(9). The district court 1 sentenced him to 77 months’ imprisonment and three years’ supervised release. Parrow appeals (1) the base-offense level of 20 under section 2K2.1(a)(4)(A) of the U.S. Sentencing Guidelines, and (2) the four-level enhancement for possessing the firearm in connection with another felony under section 2K2.1(b)(6)(B). Having jurisdiction under 28 U.S.C. § 1291, this court affirms.

Application of section 2K2.1(a)(4)(A) is reviewed for plain error because…