In order to warra nt a two-level enhance ment for possession of a fir earm, pursuant to U.S .S.G. § 2D1.1 (b)(1), is it suffic ient to simply label firearms as "tools of the trade " which allo ws for an inference of possession when possessed by a co-defendant, as is the rule in the Fifth Circuit, or must the re be reasonable foreseeability as required by the Sixth, Eight, Ninth, Eleventh and D.C. Circuits ?

Sentencing-enhancement-for-firearm-possession