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| Leader / Organizer Enhancement |
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United States v. Chisum,
No. 06-7082 (10th Cir., September 25, 2007) (Published): Federal Sentencing Guidelines; Leader/Organizer Enhancement: In this tax evasion case, the convictions are affirmed over meritless claims, but the case is remanded for re-sentencing because the District Court failed to make findings concerning Chisum's role as a leader or organizer; specifically, this enhancement requires another participant who was criminally responsible and the District Court failed to make such a finding.
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United States v. Sallis,
No. 06-7111 (10th Cir., July 18, 2008) (Published): Federal Sentencing Guidelines; Leader/Organizer Enhancement: Sallis has an a/k/a of "Triple X Gangsta" which probably does not bode well for him in this case. He was convicted in a large drug conspiracy case and sentenced to 360 months. AFFIRMED over his claims of improper enhancement for being a leader or organizer of a criminal enterprise under sec. 3B1.1, and for possession of a firearm under sec. 2D1.1.
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