United States v. Antawan D. Hudson, 695 F. App'x 528

Antawan Hudson pleaded guilty to one count of conspiracy to engage in sex trafficking of a minor and three counts of sex trafficking of a minor by force, fraud, or coercion; received a total 360-month sentence.
Hudson sought a U.S.S.G. § 3B1.2 minor-role reduction at sentencing, arguing he was less culpable than co-conspirator Maurice Williams.
Hudson’s asserted lesser role: Williams recruited him, began the conspiracy earlier, rented hotel rooms, recruited and maintained minor victims, posted ads, paid for victims’ expenses, and collected more money.
At sentencing Hudson acknowledged participating in recruiting, advertising, instructing victims, and taking proceeds, but argued these activities were lesser compared to Williams.
The district court denied the minor-role reduction; the judge who presided at Williams’s trial found Hudson and Williams were often "equal partners" with similar actions.
Hudson appealed, arguing (1) the court clearly erred in denying a minor-role reduction and (2) the court failed to make sufficient factual findings under § 3B1.2.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hudson was entitled to a minor-role reduction under U.S.S.G. § 3B1.2	Hudson: he received less money and joined later; Williams was more culpable	Government/District Court: Hudson’s conduct matched relevant conduct; he actively trafficked minors	Denied — no clear error; Hudson not a minor participant
Whether district court erred in factual findings required for § 3B1.2	Hudson: court failed to make sufficient subsidiary factual findings	Court: only ultimate role determination required; record resolved disputes	No error — findings sufficient; disputes resolved and objection overruled
Application of Rodriguez De Varon two-prong test	Hudson: less culpable compared with Williams under second prong	Court: first prong ties role to relevant conduct; second prong allows comparison but record shows parity	Court applied test correctly; Hudson failed both prongs
Whether Hudson's specific actions (recruiting, advertising, instructing, taking money) qualify as minor conduct	Hudson: those acts were less significant than Williams’s	Court: those acts were essential to trafficking; not minor	Held not minor — activities were central to operation

United States v. Bernal-Benitez, 594 F.3d 1303 (11th Cir.) (standard of review for minor-role reduction)
United States v. Rodriguez De Varon, 175 F.3d 930 (11th Cir. en banc) (two-prong test and required findings for § 3B1.2 reductions)