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United States v. Williams
Citation: 48 F. App'x 974Docket: No. 01-6358
Court: Court of Appeals for the Sixth Circuit; October 22, 2002; Federal Appellate Court
Andre Williams, a federal prisoner, appeals his sentence following a guilty plea to 8 counts of possession of stolen mail matter and 33 counts of bank fraud. He was sentenced to 21 months in prison and five years of supervised release, with restitution of $74,203 imposed jointly with his co-defendant. Williams contests the district court's decision to enhance his offense level for obstruction of justice and for a leadership role in the offense. The appellate court affirms the district court's judgment, stating that the enhancements were appropriate. Williams argues the obstruction enhancement was erroneous due to his failure to comply with a grand jury subpoena, claiming it did not significantly obstruct the investigation since some evidence was obtained from state officials. However, the court emphasizes that under USSG 3C1.1, the enhancement is warranted if a defendant willfully obstructs justice during the investigation, regardless of whether the investigation was ultimately successful. The court cites precedent affirming similar enhancements for noncompliance with grand jury subpoenas, concluding that the district court's application of the enhancement was correct. Williams's appeal on this issue is deemed without merit. The district court correctly increased Williams's offense level by two based on his role in the offense. The standard of review for such enhancements under USSG 3B1.1 involves examining the district court's factual findings for clear error and its legal conclusions de novo. However, recent case law indicates that determining eligibility for a reduction under USSG 3B1.2 for a mitigating role is also reviewed for clear error. The Supreme Court's Buford ruling supports using a deferential standard for reviewing district court applications of sentencing guidelines. The district court justified the enhancement by finding that Williams utilized his codefendant, Teresa Woods, to execute his scheme, aligning with Application Note 2, which requires the defendant to be an organizer, leader, manager, or supervisor of other participants. The court interpreted this to mean that a sentence enhancement is warranted when a defendant exerts control over at least one participant in a supervisory or managerial capacity. The credibility assessments made by the district court during the sentencing hearing must be respected. Woods's testimony, supported by other evidence, substantiated the finding that Williams supervised her during the commission of the offenses, validating the two-level enhancement. Consequently, the district court's judgment is affirmed.