Seventh Circuit - Chapter 3 Adjustments

United States v. Elmer, 980 F.3d 1171 (7th Cir. 2020). The two-level vulnerable victim enhancement at §3A1.1(b)(1) applied to a defendant who operated a compounding pharmacy and distributed adulterated drugs to members of the public, including infants.

United States v. McGee, 985 F.3d 559 (7th Cir. 2021). The court erred in imposing the two-level leadership enhancement at §3B1.1(c) on a defendant convicted of drug trafficking. No evidence suggested he exercised control or authority over, or played a superior role to, any other person in the operation.

United States v. Anderson, 988 F.3d 420 (7th Cir. 2021). The two-level leadership enhancement at §3B1.1 applied to a defendant who “directed and coordinated the entire delivery” of a single drug transaction. The defendant prearranged the logistics of the drug pickup, “maintained near-constant contact” with her codefendant who picked up the drugs, provided “step-by-step instructions for obtaining the drugs,” and confirmed that the drugs had been delivered.

United States v. Sanchez, 989 F.3d 523 (7th Cir. 2021). The court did not plainly error in refusing to apply the minor role reduction at §3B1.2(b) to a courier who transported a large quantity of drugs, recruited others, unloaded narcotics at stash houses, and prevented law enforcement from apprehending a codefendant.

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