The following excerpt is from U.S. v. Lopez-Sandoval, 146 F.3d 712 (9th Cir. 1998):
[I]t is a matter of common knowledge that some persons who have firearms in their possession commit acts of violence to avoid arrest. A person who purchases controlled substances may be defrauded or robbed of his funds prior to the transaction by unscrupulous drug dealers. A person in possession of controlled substances is also vulnerable to a [forcible] taking of his contraband by other addicts or thieves. It is clearly probable that persons who traffic in narcotics would arm themselves to avoid these hazards.
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United States v. Heldberg, 907 F.2d 91, 94 (9th Cir.1990).
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