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U.S. v. Mackey, No. 00-5666 (6th Cir.) (265 F.3d 457) (September 12, 2001) (Judge Allen E. Norris)

In this post-Bailey case, the Court held that the words "in furtherance of" in the new provisions of 18 USC § 924(c)(1)(A) requires that the gun must "promote or facilitate" the underlying crime - and mere possession is insufficient.

Following the Supreme Court's decision in Bailey v. U.S., 516 U.S. ...

 

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