United States v. Kenny Grover, 16-16313

Kenny Grover, a Georgia corrections officer, pleaded guilty to three counts of conspiracy to attempt to distribute methamphetamine and three counts of extortion under color of official right.
At sentencing the District Court imposed an 84‑month term, a downward variance from the Guidelines range.
Grover argued the government manipulated the sting (increasing drug quantity and number of transactions) to inflate his Guidelines exposure.
He also challenged a U.S.S.G. § 3B1.1(c) leadership/role enhancement applied by the District Court.
The District Court found no sentencing‑factor manipulation and applied the role enhancement; it stated it would have imposed 84 months regardless of objections.
The Eleventh Circuit affirmed: it rejected the manipulation claim on the facts and treated any Guidelines‑enhancement error as harmless because the sentence was substantively reasonable under § 3553(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the government engaged in sentencing‑factor manipulation via its sting operation	Grover: government increased drug quantity and number of transactions to inflate Guidelines exposure	Gov: reverse‑sting tactics and multiple transactions were legitimate investigative methods to identify corrupt officers	Court: No manipulation shown; precedent rejects similar claims and government conduct was not extraordinary; claim fails
Whether the district court clearly erred in applying a leadership/role enhancement under U.S.S.G. § 3B1.1(c)	Grover: court erred in finding a leadership role, which increased his offense level	Gov: enhancement was supported by facts; regardless, district court said it would impose 84 months anyway	Court: did not reach merits; any Guidelines error harmless because district court would have imposed same 84‑month sentence and that sentence is reasonable under § 3553(a)

Rodriguez‑Lopez v. United States, 363 F.3d 1134 (11th Cir.) (standard for clear‑error review of factual findings at sentencing)
Ciszkowski v. United States, 492 F.3d 1264 (11th Cir.) (reverse sting operations not manipulation absent extraordinary misconduct)
United States v. Lange, 862 F.3d 1290 (11th Cir.) (sentencing‑factor manipulation requires extraordinary government misconduct)
United States v. Keene, 470 F.3d 1347 (11th Cir.) (harmless‑error framework for Guidelines calculation errors)
Rita v. United States, 551 U.S. 338 (2007) (reasonableness review of within‑Guidelines sentences)
Gall v. United States, 552 U.S. 38 (2007) (deferential abuse‑of‑discretion review of sentencing variances)