RICHMOND, VA, October 17, 2025 — The U.S. Court of Appeals for the Fourth Circuit affirmed the conviction of Richard Brian Walker, who pleaded guilty to several drug trafficking and firearm offenses, including possession of a firearm in furtherance of a drug trafficking crime under 18 U.S.C. § 924(c)(1)(A).
Walker argued that his guilty plea lacked an adequate factual basis because most of the drugs were stored in a locked safe separate from the firearms. The appellate panel, consisting of Judges King, Richardson, and Quattlebaum, rejected that claim, finding no plain error in the district court’s acceptance of the plea.
The court held that the government’s factual proffer sufficiently linked the firearms to drug trafficking activity, noting that officers found multiple firearms and large quantities of methamphetamine on Walker’s property — including a loaded weapon under his bed and rifles stored near drugs in a shed. The panel determined that these facts supported a finding that the firearms were possessed in furtherance of a drug offense.
The Fourth Circuit affirmed the district court’s judgment without oral argument.
