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Leadership, Firearms Enhancements Upheld

By Shari Allison

U.S. v. Sallis, 2008 WL 2780594 (7/18/08) (Published) - The evidence supported a leadership upward adjustment. Supplying or fronting drugs is not enough to justify such an enhancement, but here, the defendant and his twin brother exercised joint decision-making authority re: the amount of drugs to purchase etc. and recruited others, It was also okay to enhance for firearm possession under USSG § 2D1.1, despite the acquittal on the firearm possession charge. There was evidence the defendant drove his truck while it contained both a gun and drugs.U.S. v. Sallis, 2008 WL 2787523 (7/18/08) (unpub'd) - The twin brother of the defendant in the above case could also receive a leadership enhancement. There can be more than one person in an organization who qualifies for the enhancement...continue to full post

Full post as published by Tenth Circuit Blog on July 28, 2008 (boomark / email).