U.S. v. Mitchell

Dist. Ct. did not err in sentencing defendant to life imprisonment on drug distribution charge based, in part, on finding that defendant played role in murder of confidential informant in his case. Dist. Ct. properly used preponderance of evidence standard when applying murder cross-reference under section 2D1.1 of USSG and could consider, in part, police officer's testimony that jailhouse informant had told officer that defendant had admitted to helping make arrangements to have informant killed. Fact that Dist. Ct. noted that defendant had used four different attorneys throughout criminal proceeding did not constitute 6th Amendment violation where reference was used only to support observation that defendant was merely manipulating others to avoid consequences for his own actions.