In Bailey v. United States, 116 S. Ct. 501 , 509 (1995), the Supreme Court reversed the 18 U.S.C. 924(c)(1) gun convictions of two defendants, one of whom had kept an undisclosed firearm in a footlocker in a bedroom closet and the other of whom had concealed an undisclosed firearm in the trunk of his car. The Court explained that "use" required more than "mere possession" of a firearm by the defendant. Id. at 506. Rather, the Government must show "active employment" of the firearm. Id. The "active employment" requirement is not an overly taxing one. The Court gave several examples of conduct constituting "active employment," among them, "brandishing, displaying, bartering, striking with, and most obviously, firing or attempting to fire, a firearm." Id. at 508. While the Court held that storing a concealed weapon nearby for potential use did not constitute "active employment," it noted that "an offender's reference to a firearm in his possession could satisfy 924(c)(1)." Id. Finally, the Court held out the possibility that the "carry" prong of 924(c)(1) reached conduct that the "use" prong did not. Id. at 509. In Bailey v. United States, 516 U.S. 137, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court held that "to sustain a conviction under the 'use' prong of 18 U.S.C. 924(c)(1), the Government must show that the defendant actively employed the firearm during and in relation to the predicate crime." Bailey, 516 U.S. at 150, 116 S.Ct. at 509. Active employment "includes brandishing, displaying, bartering, striking with, and most obviously, firing or attempting to fire, a firearm." Id. at 148, 116 S.Ct. at 508. The Court added that "a reference to a firearm calculated to bring about a change in the circumstances of the predicate offense is a 'use,' just as the silent but obvious and forceful presence of a gun on a table can be a 'use.' " Id. By contrast, the Court distinguished the storage or concealment of a weapon at or near the site of a drug crime by the defendant. These circumstances, the Court explained, do not satisfy the requirement of "use"; the "inert presence of a firearm, without more, is not enough to trigger 924(c)(1)." Id. Likewise, "if the gun is not disclosed or mentioned by the offender, it is not actively employed, and it is not 'used.' " Id. In Bailey v. United States, 116 S. Ct. 501 (1995) the Supreme Court narrowed the meaning of the term "uses" in 18 U.S.C. 924(c). The Court ruled that proving "use" requires"evidence to show an active employment of the firearm by the defendant." Id. at 505 "The active-employment understanding of `use' certainly includes brandishing, displaying, bartering, striking with, and most obviously, firing or attempting to fire, a firearm." Id. at 508. "`Use' must connote more than mere possession." Id. at 506. Thus, a person does not "use" a gun merely by concealing it "nearby to be at the ready for an imminent confrontation." Id. at 508. In Bailey v. United States, 116 S.Ct. 501 (1995), the Supreme Court held that a conviction under 18 U.S.C. 924(c) "requires evidence sufficient to show an active employment of the firearm by the defendant, a use that makes the firearm an operative factor in relation to the predicate offense." 116 S.Ct. at 505. Merely storing a firearm near drugs or possessing a firearm in anticipation of a possible confrontation does not constitute active use within the meaning of 924(c). Id. at 508-09. In Bailey v. United States, 116 S. Ct. 501 , 505 (1995), the Court held that the "proximity and accessibility standard provides almost no limitation on the kind of possession that would be criminalized . . . ." Id. at 506. Rather, the Court held, "18 U.S.C. Section 924(c)(1)requires evidence sufficient to show an active employment of the firearm by the defendant, a use that makes the firearm an operative factor in relation to the predicate offense." Id. at 505. The Court further explained that "the active-employment understanding of 'use' certainly includes brandishing, bartering, striking with, and most obviously, firing or attempting to fire, a firearm." Id. at 508. However, "if the gun is not disclosed or mentioned by the offender, it is not actively employed and it is not 'used.'" Id. In Bailey v. United States, 516 U.S. 137, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court held that the term "uses," as used in 18 U.S.C. 924(c)(1), which enhances the sentence of any defendant who "uses" a weapon in the commission of a federal crime of violence or drug trafficking, connotes "active employment." 516 U.S. at 144, 116 S.Ct. 501. In other words, the Court held that the Government, in prosecuting a defendant under 924(c)(1), must prove more than that the defendant merely possessed a weapon. Id. Because Bailey abrogated the overly broad definition of "uses" as it had then been interpreted by several of the circuit courts, see 516 U.S. at 142, 116 S.Ct. 501, the Court and other circuit courts subsequently recognized that defendants who had previously been sentenced pursuant to 18 U.S.C. 924(c)(1), on the basis of the erroneous definition, could attack their sentences collaterally in light of Bailey, see In re Hanserd, 123 F.3d 922, 928 (6th Cir.1997), and that they could even resort to 28 U.S.C. 2241 to do so if relief under 2255 was "inadequate or ineffective." See id. at 929-30. In Bailey v. United States, 516 U.S. 137, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court held that the term "use" should be given its "ordinary or natural meaning," requiring proof that the defendant actively employed the firearm. Bailey, 516 U.S. at 144-45, 116 S.Ct. 501. The Court reasoned that a broader interpretation of "use" would have made the inclusion of "carry" unnecessary. Id. at 145-46, 116 S.Ct. 501. By way of example, the court noted that "a firearm can be carried without being used, e.g., when an offender keeps a gun hidden in his clothing throughout a drug transaction." Id. at 146, 116 S.Ct. 501. In Bailey v. United States, 116 S.Ct. 501 (1995), the Supreme Court held that the term "use" in 18 U.S.C. 924(c)(1) requires proof of "active employment" of a weapon in order to sustain a conviction. Bailey, 116 S.Ct. at 505. However, the Court expressly distinguished the statutory term "use" from the term "possession" which may trigger a sentence enhancement under U.S.S.G. 2D1.1(b)(1): While it is undeniable that the active-employment reading of "use" restricts the scope of 924(c)(1), the Government often has other means available to charge offenders who mix guns and drugs, such as the Sentencing Guidelines 2D1.1(b)(1) which provides an enhancement for a person convicted of certain drug-trafficking offenses if a firearm was possessed during the offense. Id. at 509. Thus, the Court acknowledged that although possession is insufficient to convict under 924(c)(1), it may be sufficient to enhance a defendant's sentence under 2D1.1(b)(1). In Bailey v. United States, 516 U.S. 137, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court decided "whether evidence of the proximity and accessibility of a firearm to drugs or drug proceeds is alone sufficient to support a conviction for 'use' of a firearm during and in relation to a drug trafficking offense under 18 U.S.C. 924(c)(1)." Id. at 138-39. The Bailey court held that the "use" of a firearm during and in relation to a narcotics trafficking crime "requires evidence sufficient to show an active employment of the firearm by the defendant, a use that makes the firearm an operative factor in relation to the predicate offense." Id. at 143. The Court defined "active employment" as including "brandishing, displaying, bartering, striking with, and most obviously, firing or attempting to fire, a firearm." Id. at 148. The Bailey court rejected the theory that mere possession could constitute a "use": "The inert presence of a firearm, without more, is not enough to trigger 924(c)(1)." Id. at 149. In Bailey v. United States, U.S. 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court noted that the "carry" prong of 18 U.S.C. 924(c)(1) would bring some offenders under the reach of the statute who would not satisfy the "use" prong. U.S. at 116 S.Ct. at 509. While the Court did not directly address what was needed to establish that a defendant "carried" a weapon in relation to a drug trafficking crime, the Court clearly explained that "use" and "carry" were distinct and different from mere "possession." "The inert presence of a firearm, without more, is not enough to trigger 924(c)(1)." Id. at 116 S.Ct. at 508. The Court further explained that "a defendant cannot be charged under 924(c)(1) merely for storing a weapon near drugs or drug proceeds." Id. In Bailey v. United States, 116 S.Ct. 501(1995), the Supreme Court rejected the construction of 18 U.S.C. section 924(c)(1) used by most circuits, including this one, and held that a conviction for using a firearm in violation of " 924(c)(1) requires evidence sufficient to show an active employment of the firearm by the defendant, a use that makes the firearm an operative factor in relation to the predicate offense." Bailey, 116 S.Ct. at 505. However, the Court specifically held that " 'use' certainly includes brandishing, displaying, bartering, striking with, and most obviously, firing or attempting to fire, a firearm." Id. at 508. Under the Court's interpretation, "a firearm can be used without being carried, e.g., when an offender has a gun on display during a transaction, or barters with a firearm without handling it." Id. at 507. See Smith v. United States, 508 U.S. 223, 238-39 (1993). In Bailey v. United States, 516 U.S. 137, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court adopted a much narrower interpretation of the term "use" under 924(c)(1) and rejected the theory that the "use" prong of 18 U.S.C. 924(c)(1) could be satisfied upon a showing that the presence of the firearm "facilitated" the commission of the drug offense, or by the mere possession of a firearm by the offender. Bailey, 516 U.S. at 148-49, 116 S.Ct. 501. Instead, Bailey redefined "use" as "active employment," thereby requiring that the firearm be "an operative factor in relation to the predicate offense." Id. at 143, 116 S.Ct. 501. The types of culpable behavior that amount to "use" include: brandishing, displaying, bartering, striking with, firing or attempting to fire a firearm. Id. at 148, 116 S.Ct. 1035. Under the new interpretation of "use," liability under 924(c)(1) attaches for actual use, not intended use. Id. at 149-50, 116 S.Ct. 1035. In Bailey v. United States, 516 U.S. 137, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Supreme Court held that section 924(c)(1) requires evidence sufficient to show active employment of a firearm by the defendant, and not mere possession or intended use. See Bailey, 516 U.S. 137, 116 S.Ct. at 505-09. The Court noted also that Congress intended the terms "use" and "carry" to have "particular, nonsuperfluous meaning." Id. at 146, 116 S.Ct. at 507. Thus, according to the Court: a firearm can be used without being carried, e.g., when an offender has a gun on display during a transaction, or barters with a firearm without handling it; and a firearm can be carried without being used, e.g., when an offender keeps a gun hidden in his clothing throughout a drug transaction. Id.