5th Cir.

United States v. Mario Mata

June 10, 2026 ·25-50726 ·Per Curiam · By James Taylor

The Fifth Circuit affirmed a felon-in-possession sentence where the district court applied a sentencing enhancement for using a firearm in connection with drug trafficking. The court held that the factual finding of a connection between the firearm and drug sales was not clearly erroneous.

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Background

Mario Mata appealed his one hundred forty-four month sentence for being a felon in possession of a firearm. The district court applied a four-level enhancement under the United States Sentencing Guidelines because the firearm was found in close proximity to drugs. Mata argued the predicate felony was simple possession rather than drug trafficking.

The court’s reasoning

The court reviewed the district court’s factual finding for clear error. It found three considerations supported the enhancement. First, Mata was charged with manufacture or delivery of a controlled substance in state court, which alone is enough to support the enhancement. Second, Mata admitted to selling methamphetamine for money and carrying the firearm to protect himself during those sales. Third, Mata arranged to meet an undercover detective to smoke methamphetamine, which the court inferred was another sale given his course of dealing.

What it means going forward

This decision reinforces that a defendant’s admitted course of dealing and state drug charges can sustain a firearm enhancement even if the defendant claims the specific transaction involved giving away drugs rather than selling them.