U.S. v. Greenfield, No. 94-1001 (2nd Cir.) (44 F.3d 1141) (June 13, 1995) (Judge Guido Calabresi)
After a defendant was given a two level enhancement for his role as an "organizer", he appealed, arguing that he and his co-defendants were of equal culpability. Citing a line of cases, the Second Circuit holds that an enhancement under § 3B1.1 is inapplicable when two participants "bear equal responsibility …
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