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U.S. v. Frankhauser, No. 95-1560 (1st Cir.) (80 F.3d 641) (April 9, 1996) (Judge Hugh H. Bownes)

In this case the First Circuit reversed a trial court decision to enhance a defendant's sentence for his role as a supervisor or organizer of one other participant. The Court noted that when less than five participants are involved, the evidence must support that the defendant "exercised control over these …

 

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