United States v. Byron Metcalf-Burroughs

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 22, 2025
Docket24-1944
StatusUnpublished

This text of United States v. Byron Metcalf-Burroughs (United States v. Byron Metcalf-Burroughs) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Byron Metcalf-Burroughs, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0494n.06

No. 24-1944

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Oct 22, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE WESTERN ) DISTRICT OF MICHIGAN BYRON METCALF-BURROUGHS, ) Defendant-Appellant. ) OPINION ) )

Before: KETHLEDGE, LARSEN, and BLOOMEKATZ, Circuit Judges.

BLOOMEKATZ, Circuit Judge. Byron Metcalf-Burroughs pled guilty to possession with

intent to distribute cocaine, and the district court sentenced him within the range provided by the

Sentencing Guidelines. He now appeals the district court’s application of a two-level Guidelines

enhancement for constructively possessing a dangerous weapon during the commission of his

offense. See U.S.S.G. § 2D1.1(b)(1). He argues that his handgun was inside his home and out of

reach when the police arrested him for drug trafficking. But the district court concluded his

handgun remained accessible to him, and thus he possessed it while committing the offense. Since

this factual finding was not clearly erroneous, we affirm.

BACKGROUND

I. Arrest

The relevant facts are not disputed. In November 2023, police officers surveilled Metcalf-

Burroughs’s home, planning to arrest him for a crime unrelated to the one at issue in this case. As

Metcalf-Burroughs exited his residence to take out the trash, he noticed the police and fled on foot. No. 24-1944, United States v. Metcalf-Burroughs

He didn’t make it far before the police apprehended him and found a bag containing 13.87 grams

of cocaine on the other side of a fence he had tried to scale. When the officers searched Metcalf-

Burroughs’s person, they discovered a digital scale with white residue and green plant residue,

$2,600 in cash, and an unlabeled pill bottle with 3.35 grams of oxycodone. The police then placed

Metcalf-Burroughs under arrest.

After his arrest, officers searched Metcalf-Burroughs’s home and discovered a handgun

loaded with 16 rounds of ammunition in his bedroom, alongside his court paperwork and cell

phone. Metcalf-Burroughs’s girlfriend, who lived with him, informed the officers she believed he

possessed the handgun for self-defense since someone had recently tried to kill him. Metcalf-

Burroughs was shot in 2020 and has a bullet lodged behind his ear. Police did not recover any

drugs, narcotics, or drug trafficking tools from the residence.

II. Sentencing

Metcalf-Burroughs pled guilty to possession with intent to distribute cocaine. See 21

U.S.C. §§ 841(a)(1), (b)(1)(C). At sentencing, Metcalf-Burroughs objected to a two-level

enhancement for possessing a dangerous weapon during the commission of his offense. See

U.S.S.G. § 2D1.1(b)(1). He conceded, through counsel, that he constructively possessed the

handgun recovered from his residence. However, he argued that the government had not

established that he possessed it during his offense because it was stowed away in his bedroom,

while his drug crime took place outside of his home. The district court disagreed, explaining that

“the accessibility” of the handgun, among other factors, provided evidence that “possession was

during the commission of [the] offense.” Sentencing Hr’g Tr., R. 48, PageID 252. After applying

the two-level enhancement, it calculated Metcalf-Burroughs’s Guidelines range at 30–37 months

and imposed a within-Guidelines sentence of 34 months.

-2- No. 24-1944, United States v. Metcalf-Burroughs

Metcalf-Burroughs timely appealed.

ANALYSIS

I. Burden-Shifting Framework

To determine whether the dangerous weapon enhancement applies under § 2D1.1(b)(1),

we employ a burden-shifting framework. United States v. Kennedy, 65 F.4th 314, 318 (6th Cir.

2023). The government must first establish (1) that the defendant was in possession of a dangerous

weapon and (2) that such possession occurred during either the commission of the offense or

during “relevant conduct.” United States v. West, 962 F.3d 183, 187 (6th Cir. 2020) (quoting

United States v. Faison, 339 F.3d 518, 520 (6th Cir. 2003)). Once the government establishes these

two prongs by a preponderance of the evidence, the burden shifts to the defendant to demonstrate

it was “clearly improbable” that the weapon was connected to the offense. Kennedy, 65 F.4th at

318 (quoting U.S.S.G. § 2D1.1(b)(1) cmt. 11(A)).

Whether the defendant possessed a dangerous weapon—the first prong—is a factual

finding. United States v. McCloud, 935 F.3d 527, 531 (6th Cir. 2019). Because the government

contended Metcalf-Burroughs possessed the weapon during the actual commission of his offense,

the second prong is also a factual finding. Compare id., and United States v. Wilson, No. 22-5068,

2022 WL 17456351, at *2 (6th Cir. Dec. 6, 2022), with West, 962 F.3d at 187–88 (explaining that

when the government contends possession during relevant conduct, whether a given act “counts

as ‘relevant conduct’ . . . is a question of law”). Finally, if the burden shifts, whether the defendant

established it was “clearly improbable” that the weapon was connected to the offense is a factual

finding too. See Kennedy, 65 F.4th at 319–20. Factual findings are subject to clear error review.

McCloud, 935 F.3d at 531.

-3- No. 24-1944, United States v. Metcalf-Burroughs

II. Possession “During” the Offense

The district court found Metcalf-Burroughs possessed the handgun while he committed his

crime, and this finding is not clearly erroneous. While the handgun was not found on Metcalf-

Burroughs’s person upon his arrest, it was recovered from his residence, which he had just left to

take out the trash, and where he necessarily possessed the cocaine before leaving. The district court

explained the handgun was “certainly accessible” before he left his home and remained “easily

accessible” in his bedroom afterward. Sentencing Hr’g Tr., R. 48, PageID 252–253. Since Metcalf-

Burroughs stepped out of his home with cocaine and drug paraphernalia in tow, it was more than

reasonable for the district court to infer that he possessed those drugs with an intent to distribute

while inside his residence, where the handgun was located, just moments before his arrest.

Moreover, the district court found that the handgun remained in his possession even though it

stayed in his bedroom as he stepped outside. The district court reasoned that it was nearby, loaded,

and unlocked, just sitting next to his cell phone.

None of Metcalf-Burroughs’s counterarguments are persuasive. He urges us to compare

his case to a hypothetical one in which the firearm is hundreds of miles away from where the

defendant commits an offense. But, in such a case, the weapon would not be “easily accessible,”

nor would it have been “certainly accessible” just moments before the defendant was apprehended.

Without those findings, the analysis would be different.

Metcalf-Burroughs next argues that our caselaw always requires the government to

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Kenneth Joseph Hill
79 F.3d 1477 (Sixth Circuit, 1996)
United States v. Lavadius Faison
339 F.3d 518 (Sixth Circuit, 2003)
United States v. Greeno
679 F.3d 510 (Sixth Circuit, 2012)
United States v. Wheaton
517 F.3d 350 (Sixth Circuit, 2008)
United States v. Cobbs
233 F. App'x 524 (Sixth Circuit, 2007)
United States v. Jason Howard
570 F. App'x 478 (Sixth Circuit, 2014)
United States v. Anthony McCloud
935 F.3d 527 (Sixth Circuit, 2019)
United States v. Norman West
962 F.3d 183 (Sixth Circuit, 2020)
United States v. Zachary John Kennedy
65 F.4th 314 (Sixth Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Byron Metcalf-Burroughs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-byron-metcalf-burroughs-ca6-2025.