United States v. Payne

The First Circuit affirmed the judgment of the district court sentencing Defendant enhancing Defendant’s offense level by four levels, resulting in a guideline sentencing range of seventy to eighty-seven months in connection with its finding that Defendant had been an organizer or leader of a conspiracy of five or more persons to procure and distribute cocaine and heroin. On appeal, Defendant argued that the evidence supported only a three-level enhancement for being a “manager or supervisor,” rather than an organizer or leader. The First Circuit disagreed, holding that the uncontested factual record supported the court’s conclusion that Defendant was the leader of the criminal activity at issue. View "United States v. Payne" on Justia Law