Sentencing — supervisor enhancement

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U.S. Court of Appeals for the Seventh Circuit

Criminal

Sentencing — supervisor enhancement

Where the defendant provided cocaine to 22 co-conspirators, the district court properly enhanced his sentence for being a supervisor under U.S.S.G. 3B1.1(b).

“[T]he district judge interpreted the phone calls with co-conspirators and various threats against them as a form of supervision, going beyond merely supplying cocaine and urging prompt payment. That was a reasonable interpretation of the evidence. See United States v. Bennett, 708 F.3d 879, 892 (7th Cir. 2013) (‘Although most supervisors do not terrorize their subordinates (at least not physically), administering sanctions for poor work quality is a quintessential supervisory task.’); Weaver, 716 F.3d at 444 (‘[T]he ability to coerce underlings is a key indicator of control or authority suggestive of managerial or supervisory responsibility in the criminal enterprise.’).”

Affirmed.

12-2685 U.S. v. Ruelas-Valdovinos

Appeal from the United States District Court for the Southern District of Illinois, Reagan, J., Hamilton, J.