The following excerpt is from U.S. v. Scrivner, 116 F.3d 487 (9th Cir. 1997):
Under Bailey v. United States, 116 S.Ct. 501, 506 (1995), to sustain a conviction for "use" of a firearm under 18 U.S.C. 924(c)(1), the Government must show "active employment" of the firearm, not just mere possession.
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