which would no longer be considered criminal under Bailey’s definition of “use,” causing courts to vacate sentences or reverse these convictions. See e.g. United States v. Miller, 84 F.3d 1244 (10th Cir.1996). Reversals have been common in jury trials when it cannot be ascertained whether the jury found that the defendant was “using” the firearm, or whether it found that the defendant was “carrying” the firearm. See, e.g., United States v. Smith, 94 F.3d 122 (4th Cir.1996). Fewer cases have addressed the impact of Bailey upon eases in which the defendant pled guilty and later challenged his conviction on collateral review. In this case, Price argues that his conviction under 18 U.S.C. § 924(c)(1) ought to be set aside because no evidence established that he used a fir Cir.1996) (<HOLDING>); United States v. Riascos-Suarez, 73 F.3d 616,
holding that the defendant was carrying a gun because he transported it within reach and immediately available for use  holding that i have a gun is sufficient to justify the sentencing enhancement because it merely requires a teller to make the reasonable inference that a robber would use the gun he claimed to have if he did not receive the money he demanded holding that damages are not available for a facial challenge to a gun control law holding direct testimony tying a defendant to a gun was not required when the gun was found in the defendants truck and when the defendant had both ammunition for the gun and a rack in which it could have been kept holding that evidence was sufficient to prove defendant constructively possessed the gun where although defendant denied ownership of the gun it was found near a knife of which defendant claimed ownership and where defendant was aware of the presence of the gun