In Bousley v. United States, 523 U.S. 614, 118 S.Ct. 1604, 140 L.Ed.2d 828 (1998), the Supreme Court declined to find cause for a procedural default where a defendant failed raise the argument, at the time foreclosed in the Eighth Circuit, that he was not guilty of "using" a firearm within the meaning of 18 U.S.C. 924(c)(1). Bousley, 523 U.S. at 616, 622-23, 118 S.Ct. 1604. The Court reiterated that "futility cannot constitute cause if it means simply that a claim was `unacceptable to that particular court at that particular time.'" Id. at 623, 118 S.Ct. 1604. The Court held that, active employment of a firearm is a requirement of charging a defendant with 18 USC 924(c). Active employment includes uses such as brandishing, displaying, bartering, striking with, firing, or attempting to fire the weapon, but does not include mere possession of a firearm; thus, a defendant cannot be charged under 924(c)(1) merely for (1) storage of a weapon near drugs or drug proceeds, or (2) placement of a firearm to provide a sense of security or to embolden.