United States v. Duran Wombles, 673 F. App'x 489

Duran Wombles pleaded guilty to conspiracy to distribute heroin and being a felon in possession of a firearm; plea admitted responsibility for at least one kilogram of heroin.
He and co-defendant Lauren Summers received heroin-filled balloons from co-conspirators for street-level distribution; Summers on at least one or two occasions delivered heroin for Wombles and returned proceeds to him.
Wombles lent his truck in January 2014 to obtain a heroin “load”; law enforcement uncovered the ring via informants and controlled buys.
Presentence report documented an extremely traumatic childhood (parental drug use, sexual abuse, barter to a dealer) and significant criminal history, limited education, and addiction.
The district court applied a U.S.S.G. § 3B1.1(b) supervisor (manager/supervisor) enhancement, producing an advisory range of 210–262 months; imposed concurrent sentences of 200 months (conspiracy) and 120 months (firearm).
Wombles appealed, arguing (1) the supervisor enhancement was improper and (2) the sentence was unreasonable for insufficiently considering his abusive childhood.

Issue	Plaintiff's Argument (Wombles)	Defendant's Argument (Government / District Court)	Held
Whether § 3B1.1(b) supervisor enhancement was proper	Enhancement improper because Summers was a co-equal romantic/business partner and her limited deliveries were favors, not supervision	Wombles exercised control/authority over Summers (directed deliveries, recruited her into conspiracy), satisfying § 3B1.1(b) factors	Court affirmed: enhancement proper; control over at least one accomplice supports adjustment
Whether sentence was unreasonable for insufficiently weighing childhood trauma	Court failed to meaningfully consider mitigating effect of horrific childhood	District court acknowledged trauma but weighed it against offense seriousness, harm, recidivism, and missed reform opportunities	Court affirmed: district court considered § 3553(a) factors and did not abuse discretion

Buford v. United States, 532 U.S. 59 (explaining district courts are best situated to assess leadership/role adjustments)
Feinman v. United States, 930 F.2d 495 (prosecution must prove disputed guideline adjustments by a preponderance)
United States v. Washington, 715 F.3d 975 (deferential review of § 3B1.1 role determinations)
United States v. Vasquez, 560 F.3d 461 (supervisor enhancement proper where defendant exercised control over at least one accomplice)
United States v. Plunk, [citation="415 F. App'x 650"] (one-time direction of courier can support role enhancement)