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United States v. Hall - 101 F.3d 1174 (7th Cir. 1996)


Mere unknowing facilitators of crime are not criminally responsible participants under U.S. Sentencing Guidelines Manual § 3 B1.1. However, just as a party who knowingly assists a criminal enterprise is criminally responsible under principles of accessory liability, a party who gives knowing aid in some part of the criminal enterprise is a criminally responsible participant under the U.S. Sentencing Guidelines Manual. 


While in prison, defendant obtained methamphetamine from his girlfriend and smuggled it into the prison, intending to distribute it with the help of other inmates. The plan was discovered, and defendant pleaded guilty to one count of conspiracy to distribute methamphetamine in violation of 21 U.S.C.S. §§ 841(a)(1)846. At sentencing, the United States District Court for the Western District of Wisconsin increased defendant's base level offense for conspiracy to distribute methamphetamine, pursuant to U.S. Sentencing Guidelines Manual § 3B1.1, due to his "managerial role" in the conspiracy and his subsequent actions to obstruct justice. Defendant sought review of the sentence.


Did the district court commit reversible error when it increased defendant’s base-level sentence to conspiracy to distribute illegal drugs?




The Court of Appeals for the Seventh Circuit affirmed, noting that there was no clear error in the lower court's findings of fact at the sentencing. Defendant acted in a managerial role in relation to his girlfriend because she was under defendant's control and influence by doing his bidding to please him. Further, § 3B1.1 was applicable because there were five participants in the crime because the fifth, the drug supplier, was a person criminally responsible for the commission of the offense by providing knowing aid to the conspiracy. Defendant's perjury on a material matter was an obstruction of justice under the sentencing guidelines because it was a wilful attempt to provide false testimony.

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