United States v. Giovany Guzman, 946 F.3d 1004

Guzman was convicted by a jury of: conspiracy to possess with intent to distribute cocaine; conspiracy to import cocaine; and attempted possession with intent to distribute cocaine. He was sentenced to 190 months per count, concurrent.
After a trip to Leon, Mexico with co-defendant Oscar Gomez, Guzman texted Gomez four names/addresses (provided by co-defendant Shelby Williams); packages were shipped from Leon to those addresses.
CBP intercepted two packages labeled as exercise "steps," containing ~2.99 kg and 2.0 kg of cocaine; a third 8.7 kg package was picked up at FedEx but not inspected until later in the investigation.
Williams picked up at least one intercepted package and delivered it to Guzman; law enforcement later seized the package from Gomez’s residence.
The PSR and district court attributed all three packages to Guzman, found the total quantity exceeded five kilograms, set a base offense level of 30, applied a +3 role enhancement under U.S.S.G. § 3B1.1(b), and calculated a total offense level of 35 (CHC IV).
On appeal Guzman challenged (1) sufficiency of evidence (knowledge of contents), (2) the >5 kg quantity attribution, and (3) the § 3B1.1(b) manager/supervisor enhancement. The Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Guzman knew packages contained cocaine	Evidence (travel to Mexico, Guzman texting names/addresses, Williams picking up and delivering packages to Guzman, surreptitious conduct) permitted inference Guzman knew contents and purpose	Guzman: government failed to prove he knew the contents of any package	Affirmed—viewing evidence in light most favorable to government, a reasonable jury could find knowledge beyond a reasonable doubt
Drug-quantity attribution (>5 kg)	All three packages originated from Leon, matched addresses Guzman sent, Williams admitted picking up a FedEx package for Guzman; district court may approximate quantity where no seizure	Guzman: conceded first two packages ≈4,990 g but argued third package attribution was speculative and unsupported	Affirmed—circumstantial evidence tied third package to Guzman; court permissibly attributed at least some cocaine (≥10 g) to him, so total exceeded 5 kg
Role enhancement under U.S.S.G. § 3B1.1(b) (manager/supervisor)	Guzman used Williams to obtain names/addresses, directed her to pick up packages and meet him, and thus managed/supervised her	Guzman: argued he did not act as a manager or supervisor of participants	Affirmed—evidence supported a three-level enhancement for managing/supervising Williams (enhancement can apply where defendant managed one participant)

United States v. Vinton, 429 F.3d 811 (8th Cir. 2005) (standard for reviewing sufficiency of the evidence)
United States v. McDougal, 137 F.3d 547 (8th Cir. 1998) (jury-verdict sufficiency standard)
United States v. Marshall, 411 F.3d 891 (8th Cir. 2005) (clear-error review of sentencing facts)
United States v. Titlbach, 300 F.3d 919 (8th Cir. 2002) (standard for disturbing district court factual findings)
United States v. Atkins, 250 F.3d 1203 (8th Cir. 2001) (approving approximation of drug quantity when seizure is lacking)
United States v. Cosey, 602 F.3d 943 (8th Cir. 2010) (standard of review for § 3B1.1 enhancements)
United States v. Valencia, 829 F.3d 1007 (8th Cir. 2016) (§ 3B1.1 enhancement may apply for supervising a single participant)