The U.S. Court of Appeals for the Sixth Circuit affirmed four firearm convictions against Andre Blue, rejecting his challenge that the government presented insufficient evidence to sustain the charges. The three-judge panel issued its decision Jan. 23, 2026, in *United States v. Blue* (6th Cir. 2026).
Blue was convicted by a jury on four counts of possession of a firearm in furtherance of a drug-trafficking crime, among other offenses. He appealed only the four firearm convictions to the Sixth Circuit, arguing the evidence was insufficient to support the charges.
Writing for the panel, Circuit Judge Mathis applied the standard appellate review for sufficiency challenges, viewing the evidence "in the light most favorable to the government." Under this deferential standard, appellate courts must determine whether any rational jury could have found the defendant guilty beyond a reasonable doubt based on the evidence presented at trial.
The case originated from a 2022 investigation by the Shelby County Multi-Agency Gang Unit in Memphis, Tennessee. Investigators received information that Blue, a convicted felon, was selling fentanyl from a residence on Highland Street in Memphis. Through surveillance operations, investigators observed heavy vehicle traffic around the Highland Street location and oversaw several purchases of fentanyl at the site.
The investigation expanded when authorities learned Blue was living with his girlfriend, Laquita Bratcher, at her Memphis apartment. Surveillance at this second location revealed similar patterns of heavy vehicle traffic in and around the apartment complex. On multiple occasions, investigators observed Blue exit Bratcher's apartment, engage in hand-to-hand transactions with occupants of vehicles, and then return to the apartment.
The federal charges against Blue stem from violations of 18 U.S.C. § 924(c), which criminalizes the possession or use of firearms in furtherance of drug trafficking or violent crimes. This federal statute carries mandatory minimum sentences and requires prosecutors to prove both the underlying drug offense and that the defendant possessed a firearm in furtherance of that crime.
To establish a violation under Section 924(c), the government must demonstrate that the defendant possessed a firearm and that the possession was "in furtherance of" the drug trafficking offense. Courts have interpreted this requirement to mean the firearm must have some nexus to the drug crime, such as emboldening the defendant, protecting drugs or proceeds, or facilitating the offense.
Blue's appeal focused solely on the sufficiency of evidence supporting the four firearm convictions. Sufficiency challenges on appeal face a high bar, as reviewing courts must defer to jury verdicts and view all evidence in the light most favorable to the prosecution. The defendant bears the burden of demonstrating that no rational jury could have reached a guilty verdict based on the evidence presented.
The Sixth Circuit panel, which included Circuit Judges Boggs, Nalbandian, and Mathis, unanimously rejected Blue's challenge. The court's opinion was marked "NOT RECOMMENDED FOR PUBLICATION," indicating it will not serve as binding precedent for future cases but may be cited as persuasive authority.
The decision reflects the ongoing federal enforcement priorities targeting the intersection of drug trafficking and firearms violations. Federal prosecutors frequently pursue Section 924(c) charges in drug cases where weapons are present, as the statute provides substantial mandatory minimum penalties that can significantly increase sentences.
The case also demonstrates the effectiveness of multi-agency cooperation in drug enforcement. The Shelby County Multi-Agency Gang Unit's investigation combined local knowledge with federal prosecution resources, resulting in convictions that will likely carry substantial prison terms.
Blue's case was prosecuted in the U.S. District Court for the Western District of Tennessee before reaching the Sixth Circuit on appeal. The district court proceedings included jury selection, trial, and sentencing, though specific details about the trial proceedings and sentence imposed were not included in the appellate opinion.
The Sixth Circuit's jurisdiction includes Kentucky, Michigan, Ohio, and Tennessee, making it a key venue for federal drug and firearm prosecutions in the region. The court regularly handles appeals challenging the sufficiency of evidence in drug-related firearm cases, though published opinions addressing novel legal questions are relatively rare in this area of law.
For Blue, the affirmance means his convictions stand and any appeal options would be limited to seeking Supreme Court review through a petition for certiorari. Given the routine nature of sufficiency challenges and the lack of novel legal issues, further appellate review appears unlikely.
The decision reinforces federal prosecutors' ability to pursue firearm enhancements in drug cases where surveillance and investigation establish the nexus between weapons possession and trafficking activity. Similar enforcement patterns continue across federal districts as authorities target armed drug trafficking organizations.