In a motion for judgment of acquittal on the drug-related firearm possession count, how have the courts interpreted the "in furtherance" element of the charge?

In arguing that his motions for judgment of acquittal on the drug-related firearm possession count were erroneously denied, Savath contests only the "in furtherance" element of the offense. He argues the court erred in finding that the government sufficiently proved the specific nexus required between the gun in his bag and the drug crime.³ Evaluation of the "in furtherance" element is a fact-based inquiry requiring consideration of the totality of the circumstances. United States v. Mosley, 465 F.3d 412, 418 (9th Cir. 2006). "[S]ufficient evidence supports a conviction under 924(c) when facts in evidence reveal a nexus between the guns discovered and the

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