United States v. Byrd, No. 11-6165 (6th Cir. 2012)
Annotate this CaseByrd drove Woods to a bank. Woods entered, grabbed $2,150 from teller drawers, and returned to the car. A witness followed to an apartment complex, where they got into a car driven by Byrd’s half-brother, Jalil. Police arrived; Jalil sped away at over 90 miles per hour, running several red lights, eventually crashing into an embankment. The three fled, jumping fences and running through yards. Byrd pled guilty to robbing the bank, 18 U.S.C. 2113(a). The Presentence Report calculated a Guidelines offense level of 21, including a two-level enhancement (3C1.2) for recklessly endangerment, a two-level reduction (3E1.1(a)) for accepting responsibility, and a one-level 3E1.1(b) reduction because the probation officer anticipated a motion stating that Byrd had assisted authorities. But, because the government did not move for this reduction, the offense level was actually 22. Byrd’s extensive criminal history produced a category of IV, yielding a range of 63-78 months. The district court agreed that neither reasonable foreseeability nor merely participating as a passenger was enough to impose the reckless endangerment enhancement, but found sufficient evidence to infer that Byrd was responsible for some of the driver’s conduct. The court varied down to offense level of 21 and sentenced Byrd to 57 months. The Sixth Circuit affirmed.
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