Facts
- Frank J. Muscarello transported marijuana to a drug sale in a truck that contained a handgun locked in the glove compartment.
- Muscarello was convicted of drug trafficking and received a mandatory consecutive sentence under 18 U.S.C. § 924(c)(1) for “using or carrying” a firearm “during and in relation to” the drug trafficking crime.
- In a consolidated case, Donald E. Cleveland and Enrique Gray-Santana drove to a drug-sale location intending to steal drugs; several firearms were placed in a bag in the trunk, and agents found guns and drugs in the trunk.
- The Fifth Circuit (Muscarello) and First Circuit (Cleveland/Gray-Santana) held that transporting the firearms in a vehicle satisfied the statute’s “carries a firearm” element.
- The Supreme Court granted certiorari to resolve whether § 924(c)(1) covers a firearm located in a vehicle’s glove compartment or trunk while the defendant accompanies the vehicle.
Issues
- Whether “carries a firearm” in 18 U.S.C. § 924(c)(1) is limited to bearing a firearm on one’s person.
- Whether “carries a firearm” also includes knowingly possessing and conveying a firearm in a vehicle (including a locked glove compartment or trunk) during and in relation to a drug trafficking crime.
- Whether any remaining ambiguity requires application of the rule of lenity.
Decision
- The Court affirmed the judgments, holding that “carries a firearm” in § 924(c)(1) is not limited to on-person carriage.
- The Court held that the statute covers a person who knowingly possesses and conveys a firearm in a vehicle, including in a locked glove compartment or trunk, while accompanying the vehicle.
- The majority relied on ordinary meaning, consistent circuit authority, the statute’s purpose of addressing the combination of drugs and guns, and the absence of contrary legislative signals.
- The Court declined to apply the rule of lenity, finding no “grievous ambiguity” after considering text, context, purpose, and interpretive aids.
- A dissent argued the statutory pairing of “uses” and “carries” supports a narrower, more immediate-possession reading and that lenity should control given ambiguity and breadth concerns.
Legal Principles
- For 18 U.S.C. § 924(c)(1), “carries a firearm” includes knowingly transporting a firearm in a vehicle the defendant accompanies, even if the firearm is stored in a glove compartment or trunk.
- “Carry” may be broader than on-person bearing and can include conveyance in a vehicle when coupled with knowing possession.
- The rule of lenity applies only when, after using interpretive tools, the statute remains so ambiguous that the court can do no more than guess Congress’s intent.
Conclusion
The Court interpreted § 924(c)(1) to reach defendants who knowingly bring firearms to drug trafficking offenses by transporting them in vehicles they accompany, rejecting an on-person-only limitation and declining to apply lenity in the absence of serious ambiguity.