There must be actual possession of a firearm by a co-conspirator for the enhancement to apply on a theory of possession related to jointly undertaken criminal activity. See United States v. Vold , 66 F.3d 915, 920–21 (7th Cir. 1995) (assumption that co-conspirator possessed a firearm on a particular occasion based solely on evidence from others that he usually had a firearm was erroneous and "unwarranted"); accord, Ramirez , 783 F.3d at 690 (concluding that first step of court's inquiry was met when defendant conceded that her co-conspirators possessed four firearms in furtherance of the drug enterprise); United States v. Block , 705 F.3d 755, 763 (7th Cir. 2013). The record here includes no evidence that Michael Jones or even the buyer actually possessed a firearm in connection with the January 2018 transaction.

Information that is only a "naked or unsupported charge" is unreliable. United States v. Moreno-Padilla, 602 F.3d 802, 808-09 (7th Cir. 2010); see also United States v. Vold, 66 F.3d 915, 920 n.3 (7th Cir. 1995). Reliable, corroborated, and uncontested information reflected in the presentence report supports the district court's finding that Vasquez sold 150 grams of heroin during the August call. Although heroin was not mentioned explicitly during that phone call, the government offered an FBI agent's sworn interpretation of the conversation.

But the mere fact that Ramirez was a member of a drug-distribution ring does not make her strictly liable for all concealed weapons possessed by other conspirators. Rather, the judge was required to undertake an individualized inquiry about the foreseeability of the coconspirators' gun possession from the perspective of the defendant. United States v. Vold, 66 F.3d 915, 921 (7th Cir.1995) ; see also Luster, 480 F.3d at 558 (“[T]he district court must determine that the coconspirator's firearm possession was reasonably foreseeable to the defendant. ”) (emphasis added).

United States v. Strode, 552 F.3d 630, 635 (7th Cir.2009). It is the government's burden to “establish the appropriateness of the enhancement by a preponderance of the evidence.” United States v. Vold, 66 F.3d 915, 920 (7th Cir.1995). Though it is a close call, we cannot conclude that the two-level enhancement of Peeples's offense level was supported by this record.

United States v. Strode, 552 F.3d 630, 635 (7th Cir. 2009) (citing United States v. Acosta, 534 F.3d 574, 588 (7th Cir. 2008)). King relies on United States v. Vold, 66 F.3d 915 (7th Cir. 1995), to argue that she could not have reasonably foreseen Underwood's possession of the .45 caliber pistol in furtherance of their conspiracy. In Vold, the district court enhanced a defendant's Guidelines range for possession of a firearm, concluding that his coconspirator's possession of the weapon was reasonably foreseeable to him based on the coconspirator's use of the weapon and the fact that weapons are commonly used in drug manufacturing conspiracies.

A defendant's sentence may be enhanced under § 2D1.1(b)(1) if the defendant possessed a firearm during the commission of her offense, or if a co-conspirator possessed the firearm while acting in furtherance of the conspiracy and the co-conspirator's possession was reasonably foreseeable to the defendant. See United States v. Vold, 66 F.3d 915, 920 (7th Cir. 1995); U.S.S.G. § 1B1.3(a)(1)(B). In one of the audio tapes introduced into evidence, Griffith identified himself and Montague as the speakers.

Id. (emphasis added). However, the Defendant did argue that a "reasonable foreseeability" finding was required for § 2D1.1 enhancements for co-conspirator conduct, citing instead to United States v. Vold, 66 F.3d 915 (7th Cir. 1995) (requiring a reasonable foreseeability finding, in conjunction with § 1B1.3(a)(1)(b), for § 2D1.1(b)(1) firearms possession enhancements based on co-conspirator conduct). The United States countered that § 2D1.1(b)(1) did not require reasonable foreseeability, and that, in any event, Gallo could reasonably have foreseen her co-conspirators' firearms possession.

The mere fact that Overton referred to the 20-ounce transaction only on one occasion certainly does not render the decision to attribute the crack to Hardamon unreliable. See United States v. Vold, 66 F.3d 915, 918 (7th Cir. 1995) ("[t]he testimony of one witness . . . is sufficient to support a finding of fact"); see also United States v. Rivera, 6 F.3d 431, 445 (7th Cir. 1993). Furthermore,:

The government must prove that this enhancement is warranted by a preponderance of the evidence. United States v. Vold, 66 F.3d 915, 920 (7th Cir. 1995); United States v. Mumford, 25 F.3d 461, 465 (7th Cir. 1994). We review a district court's factual determination to enhance a sentence under sec. 2D1.1(b)(1) for clear error only. See, e.g., United States v. Berchiolly, 67 F.3d 634, 640 (7th Cir. 1995); United States v. Covarrubias, 65 F.3d 1362, 1370 (7th Cir. 1995).

We review the district court's calculation of quantity of narcotics attributable to Benitez for clear error. United States v. Taylor, 72 F.3d 533, 542 (7th Cir. 1995); United States v. Vold, 66 F.3d 915, 918 (7th Cir. 1995). "We will reverse the sentencing court's determination of drug quantity only if we are left with a `definite and firm conviction that a mistake has been made.'"