Trading Guns for Drugs Satisfies "In Furtherance" Req't of 924(c)

U.S. v. Luke-Sanchez, --- F.3d ----, 2007 WL 1128878 (10th Cir. April 17, 2007)

D who traded meth for guns was properly convicted of possessing a firearm in furtherance of a drug trafficking crime, 18 USC Sec. 924(c). The “in furtherance of” language was added in 1998 and the 10th holds that it encompasses trading guns for drugs. For the same reason, his objection to the jury instruction (can find hm guilty if he traded drugs for guns) fails.