Eighth Circuit - Chapter 3 Adjustments

United States v. Jefferson, 975 F.3d 700 (8th Cir. 2020). The court did not clearly in applying §3B1.1(c)’s 2-level adjustment for aggravating role. The defendant’s girlfriend testified that the defendant instructed her how to package drugs for sale, directed her to conduct deliveries, ordered her to install a lock on the door where the drugs were stored, had her purchase a firearm and ammunition to protect the drug conspiracy, and managed funds derived from and used in the conspiracy.

United States v. Cooper, 998 F.3d 806 (8th Cir. 2021). A court may deny a 2-level reduction for acceptance under §3E1.1(a) based on a defendant’s pre-plea criminal conduct.

United States v. Boll, 3 F.4th 1099 (8th Cir. 2021). A 2-level vulnerable-victims adjustment under §3B.1(b)(2)(B) applied in a case where the defendant, a hospice nurse, stole opioids and other paid medications from 14 patients.

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