United States v. Lee Logan
CourtCourt of Appeals for the Sixth Circuit
Date FiledOctober 23, 2026
Docket25-1934
JudgeEugene E. Siler, Jr.; Karen Nelson Moore; Jeffrey S. Sutton
StatusUnpublished
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Full Opinion
NOT RECOMMENDED FOR PUBLICATION
File Name: 26a0432n.06
Case No. 25-1934
UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT FILED
Oct 23, 2026
KELLY L. STEPHENS, Clerk
)
UNITED STATES OF AMERICA,
)
Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED
) STATES DISTRICT COURT FOR
v. ) THE WESTERN DISTRICT OF
) MICHIGAN
LEE LOGAN, )
Defendant-Appellant. ) OPINION
)
Before: SILER, MOORE, and SUTTON, Circuit Judges.
SILER, Circuit Judge. Defendant Lee Logan appeals his sentence. We AFFIRM.
I. Background
In 2024, Logan sold crack cocaine to a confidential informant (“CI”) near a residence.
Within five days of the transaction, investigators obtained a search warrant for the residence.
Before executing the warrant, investigators witnessed Logan approaching the residence on foot.
The investigators told Logan to stop, but he fled. As law enforcement chased and tackled Logan,
a loaded .380 caliber pistol fell from his waistband. A search of Logan’s person revealed 2.21
grams of cocaine and 0.94 of a gram of fentanyl. Logan claimed the drugs were for personal use
and that the gun was for his protection.
Upon searching the residence, investigators discovered evidence of low-level drug
trafficking, including digital scales and a Pyrex cup with residue. In a bedroom closet,
investigators found .380 caliber ammunition next to a pill bottle bearing Logan’s name.
Investigators found four other people in the residence during the search.
No. 25-1934, United States v. Logan
Following the incident, the government indicted Logan on one charge: possession of a
firearm as a convicted felon in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8). Logan
subsequently pled guilty without a plea agreement to the indicted offense.
Prior to sentencing, probation issued a presentence report (PSR), which applied the federal
sentencing guidelines to calculate Logan’s offense level and criminal history category. The PSR
assigned Logan a base offense level of 24 because Logan committed the instant offense while
having two prior controlled substance offenses. The PSR then assigned an additional four levels
pursuant to USSG § 2K2.1(b)(7)(B)1 because Logan possessed a firearm in connection with
another felony offense—distribution of cocaine base. The PSR then subtracted three offense levels
for acceptance of responsibility, resulting in a total offense level of 25. In addition, because of his
prior criminal convictions, the PSR assigned Logan a criminal history score of 15, thus establishing
a criminal history category of VI.
In an addendum to the PSR, Logan objected to the recommended USSG § 2K2.1(b)(7)(B)
sentencing enhancement, arguing that his firearm did not facilitate or have the potential of
facilitating another offense. Logan contended that he was merely “a drug user” and that the gun
was not found in connection with any drug transaction.
At sentencing, Logan’s counsel appeared to concede that Logan had sold drugs to the CI.
Indeed, Logan’s counsel noted that “[a]s the government says, five days prior to [Logan’s arrest]
. . . he had sold drugs to a [CI].” But Logan challenged the four-level enhancement because “there
are no facts which support that he was armed at the time of any drug deal.” Logan also contended
that the quantity of drugs found on his person during his arrest “could easily be user quantity.”
1
The PSR cites USSG §2K2.1(b)(6)(B) as the source of the sentencing enhancement, but that
enhancement has been moved to USSG § 2K2.1(b)(7)(B). For the sake of clarity and consistency,
we refer to the enhancement where it is now codified, at USSG § 2K2.1(b)(7)(B).
2
No. 25-1934, United States v. Logan
In response, the government averred that Logan was carrying a gun for protection and that he “was
seen selling drugs from a house where drug trafficking materials were found.”
Addressing USSG § 2K2.1(b)(7)(B), the district court noted the government’s concession
that “Logan was not involved in a drug transaction on the day of his arrest.” But it recognized that
Logan had sold drugs to the CI “within a few days of his ultimate arrest.” And the court
emphasized that investigators found “scales and plastic baggies” in the residence. Finally, the
court stated that Logan’s admission that he used his firearm for “protection” in conjunction with
the discovery of paraphernalia further suggested that the gun facilitated or had the potential to
facilitate drug trafficking.
The district court thus determined that the applicable sentencing range was 110 to 137
months. It then heard the parties’ arguments regarding the 18 U.S.C. § 3553(a) sentencing factors,
Logan’s allocution, and imposed a sentence of 132 months.
II. Discussion
On appeal, Logan argues that the district court committed reversible error by applying the
USSG § 2K2.1(b)(7)(B) sentencing enhancement because (1) the record does not show that Logan
was involved in distributing drugs when he was arrested and (2) the residence containing evidence
of drug distribution was insufficiently connected to Logan. In response, the government points to
evidence justifying the enhancement, including evidence that Logan sold drugs to the CI, that
Logan had drugs and a gun on his person when arrested, and that the searched residence had
evidence of Logan’s presence and drug distribution.
According to its own terms, the USSG § 2K2.1(b)(7)(B) sentencing enhancement applies
if the defendant “used or possessed any firearm or ammunition in connection with another felony
offense.” Thus, the enhancement contains three essential elements: “(1) use or possession of a
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No. 25-1934, United States v. Logan
firearm; (2) in connection with; (3) another felony.” United States v. Clay, 187 F.4th 493, 501
(6th Cir. 2026) (citing United States v. Seymour, 739 F.3d 923, 929 (6th Cir. 2014)). And the
government must establish each of these elements by a preponderance of the evidence. Id. Further,
the commentary to USSG § 2K2.1 explains that the (b)(7)(B) enhancement applies “if the firearm
. . . facilitated, or had the potential of facilitating, another felony offense.” USSG § 2K2.1 cmt.
n.13. So, the government need not show that the firearm facilitated another felony offense;
potential for facilitation is enough. See id. That said, the government must establish more than a
“merely coincidental” connection between the underlying felony and the firearm possession.
Seymour, 739 F.3d at 929 (quoting United States v. Angel, 576 F.3d 318, 321 (6th Cir. 2009)).
The district court did not commit reversible error by finding that the government had
established the USSG § 2K2.1(b)(7)(B) enhancement by a preponderance of the evidence.
Satisfying the first element of the enhancement (firearm possession), Logan admitted to possessing
a firearm.
Satisfying the third element of the enhancement (another felony offense), the record
establishes that Logan distributed drugs because he sold drugs to a CI days before the arrest—
Logan did not contest the drug transaction at sentencing. Also supporting the third element, the
firearm could have facilitated additional drug distribution because Logan had drugs and a firearm
during his arrest and was arrested outside a residence that contained both evidence of drug
distribution and some of his personal belongings.
Finally, regarding the second element (nexus), the drug transaction with the CI, the
discovery of drugs and a gun on Logan’s person during his arrest, and the contemporaneous
proximity of a residence containing evidence of drug distribution and Logan’s belongings
sufficiently establish a connection between Logan’s firearm possession and drug distribution.
4
No. 25-1934, United States v. Logan
Stated differently, there was a consistent theme of drug distribution and the potential for Logan to
use his firearm to facilitate drug distribution, particularly at the time of his arrest. Thus, the district
court properly applied the USSG § 2K2.1(b)(7)(B) sentencing enhancement.
In response to the above, Logan first argues that the district court incorrectly concluded
that Logan participated in a controlled buy. Second, Logan urges that there is little evidence
showing that he lived at the residence searched by investigators. Third, Logan contends that he is
a mere drug user and that any link between firearm possession and drug distribution is coincidental.
Thus, Logan attacks the evidence suggesting that he engaged in drug distribution and the evidence
indicating a connection between firearm possession and drug distribution.
Regarding the district court’s characterization of Logan’s drug transaction as a controlled
buy, Logan’s argument misses the point. The district court’s primary concern was that Logan sold
drugs to the CI. And the CI’s representations to investigators, combined with the other evidence
of drug trafficking, corroborate that Logan sold drugs to the CI. So, the district court did not
clearly err on this front.
Logan’s second argument—that the district court committed clear error by finding that
Logan lived at the residence searched by law enforcement—is likewise unconvincing. The court
addressed whether there was a connection between Logan, his firearm possession, and the
residence. Again, Logan sold drugs to the CI just outside the residence. Investigators arrested
Logan while he was returning to the residence with drugs and a gun. And the residence itself
contained evidence of drug distribution along with a pill bottle bearing Logan’s name and
ammunition for his firearm. So, the record supports the district court’s finding.
Finally, the record contradicts Logan’s contention that he is a mere drug user and his
argument that the connection between firearm possession and drug distribution is coincidental.
5
No. 25-1934, United States v. Logan
For one, regarding the mere-user argument, the district court did not find a connection between
the drug trafficking and firearm possession based solely on the drugs found on Logan’s person.
Indeed, the court agreed with the government’s concession that “Logan was not involved in a drug
transaction on the day of his arrest.” The court found a nexus based on a recent drug sale, Logan’s
connection to the residence, and his admission that he possessed the firearm for protection.
To argue that the drugs and guns were coincidentally linked, Logan relies on United States
v. Briggs, 919 F.3d 1030 (7th Cir. 2019). But Briggs is distinguishable. For one, the underlying
felony in Briggs was drug possession—a crime different in kind from drug distribution. See id. at
1032-33. Most important, however, the Briggs court emphasized that the district court made no
findings of fact tying the defendant’s firearm possession to his possession of drugs. Id. at 1033.
Here, the district court made relevant findings of fact. So, Briggs is unlike the case here.
Logan further contends that United States v. Shields, 664 F.3d 1040 (6th Cir. 2011),
supports his reasoning. But again, the underlying offense in Shields was drug possession, not
distribution. Id. at 1044. And nothing in Shields tied the defendant’s possession of a firearm to
his possession of a small quantity of drugs. Id. at 1044-46. Here, by contrast, Logan possessed a
firearm for protection while carrying drugs back to a residence that contained evidence of drug
distribution. Therefore, Shields does not help Logan either.
III. Conclusion
For the above reasons, we AFFIRM the judgment of the district court.
6