United States v. Antoine Owens, 437 F. App'x 436

Owens appeals a 63-month sentence after pleading guilty to conspiracy to violate civil rights (18 U.S.C. § 241).
District court calculated total offense level 29, criminal history I, and a guideline range of 87–108 months; denied minor-participant reduction.
Court granted a 24-month departure for substantial assistance under § 5K1.1, resulting in 63 months.
Robbery/entrapment at a Walgreens parking lot: Owens stopped a truck, searched victims, confiscated cash, and transported a victim with Sease and Johnson.
Sease, a Memphis police officer, paid Owens for assistance; Sease later split cash with Owens and Johnson; Owens played an active sequencing role.
Owens argued for a minor-participant reduction and for Rule 32(i)(3) findings; appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Owens was entitled to a minor-participant adjustment	Owens was a minor participant	Owens acted as a minor, expendable participant	No; Owens did not play a minor role in the Walgreens robbery
Whether Rule 32(i)(3) required independent factual findings	Rule 32(i)(3) required findings beyond PSR	Undisputed facts allowed reliance on PSR	Rule 32(i)(3) findings not required where facts undisputed

United States v. Lloyd, 10 F.3d 1197 (6th Cir. 1993) (defines minor-participant standard and guidance for review)
United States v. Lanham, 617 F.3d 873 (6th Cir. 2010) (review for clear error in denying mitigating role)
United States v. Salgado, 250 F.3d 438 (6th Cir. 2001) (limits on minor-participant reduction in conspiracy)
United States v. Campbell, 279 F.3d 392 (6th Cir. 2002) (role in conspiracy governs minor-participant denial)
United States v. White, 492 F.3d 380 (6th Cir. 2007) (Rule 32(i)(3) compliance—de novo review)
United States v. Treadway, 328 F.3d 878 (6th Cir. 2003) (accept undisputed facts from PSR as findings)
United States v. Freeman, 640 F.3d 180 (6th Cir. 2011) (affirming reliance on PSR where no dispute)