U.S. v. Payne, No. 94-1613 (2nd Cir.) (63 F.3d 1200) (August 23, 1995) (Judge Amalya Lyle Kearse)
One of the holdings in this case was that the requirements of § 3B1.1 are met if the defendant was a manager or supervisor and the criminal activity itself involved at least five participants; but the defendant need not be the manager of more than one other person. Referring to …
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