United States v. McKinney, No. 20-1265 (1st Cir. 2021)
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The First Circuit affirmed Defendant's conviction and sentence imposed after he pled guilty to drug and firearm conspiracy counts, holding that the district court did not err in concluding that Defendant was a manager or supervisor of the drug conspiracy and applying a three-level enhancement.
In sentencing Defendant, the district court found that he qualified for a three-level enhancement for being a manager or supervisor of the drug and firearm conspiracies, pursuant to U.S.S.G. 3B1.1(b). On appeal, Defendant argued that the district court's conclusion that he was a manager or supervisor of the drug conspiracy because he directed people to buy firearms and told them where to drive was erroneous. The First Circuit affirmed, holding that, in light of the evidence, the district court correctly applied the section 3B1.1(b) enhancement.
The court issued a subsequent related opinion or order on July 22, 2021.
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