Palmer, along with a fellow associate, were driven to the house of the rival trafficker and subsequently killed him.

However, the judge vacated the § 848 charge due to insufficient evidence proving the quantity of drugs.

The United States Court of Appeals for the Second Circuit affirmed, which had established a precedent in its case law that 924(j) "incorporates the entirety of [subsection 924(c)],” including the bar on consecutive sentences at § 924(c)(1)(D)(ii).

On June 16, 2023, the Supreme Court unanimously vacated the Second Circuit's judgment and remanded.

Sections 924(c) and 924(j), Jackson points out, criminalize the use, carrying, and possession of firearms in connection with certain crimes.