United States v. Ronald Cowan

OPINION

CONTIE, Circuit Judge.

Defendant-appellant Ronald Cowan (“Cowan”) let a friend use his gun to commit an armed robbery. On appeal, Cowan asserts that he should not be held accountable for his friend’s use of the firearm under United States Sentencing Guideline § 2B3.1(b)(2)(C). We reject Cowan’s argument and therefore affirm the district court’s sentencing determinations.

I

On July 10, 1997, a young man (hereinafter “the juvenile”) carrying a sawed-off rifle entered a Payless Beauty Supply store in Memphis, Tennessee. The juvenile pointed the weapon at the store clerk’s face and demanded…