Smith v. United States (1993)

Smith v. United States, 508 U.S. 223 (1993), is a United States Supreme Court case that held that the exchange of a gun for drugs constituted "use" of the firearm for purposes of a federal statute imposing penalties for "use" of a firearm "during and in relation to" a drug trafficking crime.

In Watson v. United States, 128 S.Ct. 697 (2007) the court later decided that a transaction in the opposite direction does not violate the same statute (i.e., Smith holds that one "uses" a gun by giving it in exchange for drugs, but Watson holds that one does not "use" a gun by receiving it in exchange for drugs).

Statutory Context and Sentencing
The defendant exchanged a firearm for cocaine and was convicted of drug trafficking. The prosecution claimed this triggered enhanced sentencing because of the "use" of the gun in the commission of a crime. The defendant stated using a firearm for barter was not covered by the statutory meaning of "use". The Supreme Court had found that in a subsection of the statute, firearms could be 'used' as objects of commerce rather than as weapons, implying that a similar understanding and interpretation of 'used' should apply to the disputed sentence.