Defining "use" as "active employment" required the Court to remand the cases for further proceedings. Bailey's gun was in the trunk of his car; there was no evidence that he was actively employing the gun at the time of his arrest. Similarly, Robinson's gun was in a locked footlocker in her bedroom closet. But the court of appeals had not considered whether the "carry" prong supported the convictions, so the Court remanded the case for further proceedings.
