Firearms Cross-Reference Discussed

U.S. v. Valdez, 2007 WL 2693854 (9/10/07)(unpub'd) - USSG § 2K2.1(c)(1), which provides for cross-referencing to a higher guideline if a firearm is used or possessed in connection with "the commission of another offense," applies even if the defendant did not use the firearm. The analysis for (c)(1) is no different than the analysis under § 2K2.1(b)(6), which provides for enhancements for using or possessing a firearm "in connection with another felony offense."