United States v. David MacLloyd, 526 F. App'x 434

Brothers David and Clifford MacLloyd were Detroit-area cocaine wholesale dealers in 2007–2008; David handled finances while Clifford distributed drugs.
Serrano supplied cocaine via a network including Sanabria; Santiago transported drugs and money; Ochoa later drove drugs between Arizona and Michigan.
Ochoa and Green operated drug shipments, using vehicles with hidden compartments; Green made 7–10 trips with ~40 kilograms per trip.
Defendant eliminated Ochoa from the operation in 2008 and sought direct dealings with Serrano for larger shipments.
DEA investigated in 2008; multiple seizures occurred, including kilograms of cocaine, firearms, and large cash sums at properties Defendant rented or controlled.
Defendant was convicted on counts including conspiracy, possession with intent to distribute, use of a communications facility, and maintaining drug-involved premises; sentence imposed ran concurrently.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for Counts 1 and 2	MacLloyd knew of and controlled the conspiracy.	Only buyer-seller relations; no agreement.	Evidence supported conspiracy and aiding-and-abetting; sufficient for Counts 1 and 2.
Sufficiency of evidence for Count 26	Premises were used for drug distribution.	Insufficient proof of use of four listed premises.	Sufficient evidence any one listed premises was maintained as drug-involved.
New-trial grounds based on discovery and witness matters	Government withheld favorable disclosures and informant details.	Violations require new trial.	No reversible error; no plain error in disclosure or witness handling.
Confrontation and Grace’s dual-role testimony	Grace testified as fact and expert; dual-role instruction needed.	Plain error if not properly instructed.	No plain error; district court properly addressed Grace’s dual role.
Leadership role enhancement and sentence disparity	Enhanced for leadership; disparity with co-defendants is unwarranted.	Enhancement and disparity were improper.	Four-level leadership enhancement affirmed; no reversible disparity in light of co-defendants.

Jackson v. Virginia, 443 U.S. 307 (U.S. (1979)) (sufficiency review standard: rational juror could find guilt beyond reasonable doubt)
Crayton, 357 F.3d 560 (6th Cir. 2004) (elements of conspiracy require agreement and intent)
Hereford, 162 F. App’x 439 (6th Cir. 2006) (buyer-seller relations do not alone prove conspiracy; large purchases may infer conspiracy)
Sills, 662 F.3d 415 (6th Cir. 2011) (repeated purchases from a single source support conspiracy inference)
Gunter, 551 F.3d 472 (6th Cir. 2009) (evidence of large-scale drug operation supports conspiracy finding)
Caver, 470 F.3d 220 (6th Cir. 2006) (concerted effort and shared objectives support conspiracy)