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U.S. v. Valdez-Arieta, No. 97-8014 (10th Cir.) (127 F.3d 1267) (October 29, 1997) (Judge David M. Ebel)

Case held that role as "organizer" does not require proof that defendant exercised control over subordinates.

The principal issue raised on this appeal was whether the district court had erred by imposing a two-level sentence enhancement, under U.S.S.G. ยง 3B1.1(c), for the defendant's role as an "organizer" of a criminal ...

 

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