United States v. Antoine Matthews
16-3354
| 7th Cir. | Dec 15, 2017Background
- Matthews obtained >10 kg of heroin from a Mexican supplier (Oct 2011–Oct 2012) and distributed wholesale to Cleveland.
- Four transactions: July 4 and July 27 deals in Joliet; August 21 purchase where Matthews sent associates Lamar Egler and Lewis Hall with $330,000 to buy ~6 kg; October 6 deal where Matthews brought three others after Egler and Hall were arrested. Matthews was arrested at the October 6 meeting.
- Wiretapped calls show Matthews coordinating deals, instructing couriers (e.g., when to count money, when to wait for supplier), and directing others’ actions.
- At sentencing the probation officer sought a +4 organizer/leader enhancement under U.S.S.G. § 3B1.1; the judge applied a +3 manager/supervisor adjustment, finding five or more participants and that the activity was otherwise extensive.
- Matthews objected, arguing he did not exercise supervisory authority, the participants were independent dealers or mere bystanders, and the enterprise was not sufficiently extensive.
- The district court affirmed the +3 adjustment at resentencing and imposed a 156‑month term; the Seventh Circuit affirmed, finding no clear error in the manager/supervisor enhancement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 3B1.1 enhancement for manager/supervisor (+3) was warranted | Government: Matthews directed others, instructed couriers, replaced detained runners, and oversaw multi‑kg transactions | Matthews: intercepted calls show guidance not control; participants were independent or merely present; activity not extensive | Affirmed: record supports that Matthews supervised couriers and the activity was otherwise extensive; no clear error |
Key Cases Cited
- United States v. Weaver, 716 F.3d 439 (7th Cir. 2013) (no single factor required to apply § 3B1.1 enhancement)
- United States v. Grigsby, 692 F.3d 778 (7th Cir. 2012) (role‑in‑offense factors guide organizer vs manager distinction)
- United States v. Figueroa, 682 F.3d 694 (7th Cir. 2012) (supervisor characterized as one who tells others what to do and verifies performance)
- United States v. Leiskunas, 656 F.3d 732 (7th Cir. 2011) (clear‑error review standard for role‑in‑offense findings)
- United States v. Ruelas‑Valdovinos, 747 F.3d 941 (7th Cir. 2014) (unchallenged factual statements can bolster role findings)
- United States v. Thompson, 777 F.3d 368 (7th Cir. 2015) (sentencing‑conditions remand issues)