U.S. v. Michalek, No. 94-1450 (7th Cir.) (54 F.3d 325) (April 26, 1995) (Judge Kenneth F. Ripple)
Court rejected contention that enhancements for more than minimal planning under § 2F1.1(b)(2) and aggravating role under § 3B1.1 constituted impermissible double counting.
There is a good listing, at 14 on page 334 of this case, of cases in most of the circuits that have approved the imposition of both …
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