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interpretation
Given ordinary meaning and the conventions of English, we hold that a person does not “use” a firearm under § 924(c)(1)(A) when he receives it in trade for drugs.
Given ordinary meaning and the conventions of English, we hold that a person does not “use” a firearm under § 924(c)(1)(A) when he receives it in trade for drugs.
Source: docroot/ir/caselaw/us_552.jsonl#/us/552/0074-01; Unicode character offsets [12492:12654] (end exclusive); SHA-256 728193ba55a5222dee7b27c3696113257607f4c90607bd00a029d36e118e75e2.
Bailey predates the 1998 possession amendment. Its active-employment rule still defines use; it does not immunize possession in furtherance. Watson decides use only and expressly leaves the possession theory open.