United States v. Hilliard
United States Court of Appeals for the Eighth Circuit
490 F.3d 635 (2007)
Tyrone Hilliard (defendant), a convicted felon, was found with cocaine and a handgun during an earlier search of his house. Six months later, officers witnessed him engage in an apparent drug transaction at the same house, then found cash, valuables, cocaine, drug-packing materials in the kitchen, and a handgun under a pillow in his bedroom down the hall. Hilliard admitted keeping the cocaine to pay bills and admitted illegally possessing the gun, saying it was for personal protection, and a police detective testified that drug dealers commonly keep firearms nearby for protection during trafficking. Hilliard was convicted of possessing a firearm in furtherance of drug trafficking and appealed, arguing insufficient evidence connected the gun to the drug offense.
Whether the evidence was sufficient to prove a nexus between a defendant's firearm and his drug-trafficking offense, where the gun was found near drugs, cash, and packaging materials but there was no direct proof the gun was used in a specific transaction.