Sentence Enhancement-Clear Error

7^th Circuit Court of Appeals

Case Name: United States of America v. Malaia Turner

Case No.: 24-2735

Officials: Hamilton, Kirsch, and Kolar, Circuit Judges.

Focus: Sentence Enhancement-Clear Error

Turner was charged with conspiring to distribute 500 grams or more of methamphetamine. At trial, the government presented evidence that, beginning in 2019, Turner and Marcus Posey operated a methamphetamine trafficking operation that transported drugs from California to Illinois. Turner played a significant role in the conspiracy by purchasing, packaging, and shipping methamphetamine, recruiting drug couriers, coordinating transactions, negotiating drug deals, collecting payments from customers, and personally handling large-scale sales. As the operation expanded, Turner and Posey shared the proceeds and jointly determined pricing.

Turner was convicted in the Central District of Illinois. Before sentencing, the probation office prepared a Presentence Investigation Report (PSR) recommending a two-level aggravating-role enhancement under U.S.S.G. § 3B1.1(c) based on Turner’s leadership role and attributing substantial drug quantities to her. Turner objected to both the drug quantity calculations and the proposed enhancement. The district court rejected those objections, adopted the PSR’s factual findings, and sentenced Turner to 324 months’ imprisonment. Turner then challenged the sentencing procedures and the application of the leader-organizer enhancement.

The Seventh Circuit found that the evidence supported the two-level leader-organizer enhancement because Turner exercised supervisory authority over other participants and played a significant managerial role in the conspiracy. The court also concluded that the district court did not clearly err in attributing the challenged drug quantities to Turner. Although Turner alleged procedural errors in the sentencing process, the court determined that any such errors were harmless because they did not affect the sentence imposed.

Affirmed.

Decided 06/29/26

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