Federal 7th Circuit Court
Criminal Court
Sentencing
Dist. Ct. did not err in sentencing defendant to 20-month, below Guidelines term of incarceration, where said sentence was based in part on imposition of 2-level upward adjustment under section 3B1.1(c) of USSG for defendant’s role as organizer in said offense. While defendant argued that information in pre-sentence report indicating that he organized instant offense by obtaining false documents and referred buyers to co-defendant loan officers was insufficient to establish type of coercion necessary to support imposition of instant enhancement, coercion is just one factor when applying section 3B1.1(c) of USSG. Moreover, record otherwise supported imposition of said enhancement, where: (1) defendant rewarded others in scheme with continued business; and (2) defendant influenced criminal activity by coordinating efforts of others to advance scheme.