Held, as originally enacted, § 924(c)(1)(A) applied only to a defendant who "used or carried a firearm" "during and in relation to any... drug trafficking crime. Congress added the "possession in furtherance" prong to the text in 1998, shortly after the Supreme Court ruled that mere possession of a gun in the vicinity of a drug transaction did not constitute "use" under § 924(c)(1)(A), Had Congress intended possession alone to trigger liability under § 924(c)(1), it easily could have so provided.
The Court had earlier held that § 924(c)(1)(A)'s "use" provision applied to a defendant who bartered a firearm for drugs. (Smith v. United States). Watson clarified that the term "use" did not extend to the opposite situation, in which a defendant exchanged drugs for guns. Watson noted Congress's amendment to add the "possession in furtherance" prong of the statute, but explicitly did not address the amended statute's application to such exchanges.
For purposes of 18 U.S.C. § 924(c)(1)(A), "we have understood 'in furtherance of' to demand showing a sufficient nexus between the firearm and the drug crime such that the firearm advances or promotes the drug crime." On the facts to which Defendant pled guilty, there was an ample nexus between his possession of the Bryco semi-automatic pistol and the drug trafficking crime charged in Count Six. Appeal dismissed.
