United States v. Manuel Verduzco, 558 F. App'x 562

Verduzco pleaded guilty to conspiracy to distribute and possess with intent to distribute cocaine and was sentenced to 180 months; the district court denied acceptance of responsibility credit and applied a 3-level managerial enhancement; Verduzco appeals both sentencing rulings and the overall reasonableness of the sentence.
Verduzco conspired with his nephew Edgar to run a cocaine trafficking operation from California to Michigan; co-conspirators (Edgar, Orlando, Olague, Rodriguez) arranged transportation of cocaine and other logistics.
In 2010 law enforcement recovered five 1-kilogram packages of cocaine and a GPS unit pointing to Grand Rapids; Verduzco instructed others to abandon a residence and discard phones, and he rented motel rooms for the group.
Mondragon, a later supplier, sold cocaine and Verduzco later agreed to drive Edgar to California with Rodriguez to pay for the drugs; Mondragon identified Edgar as a cocaine source to law enforcement.
Verduzco fled to Mexico after 2010, returned to the U.S. after being shot and his daughter killed, and claimed this indicated fear and injury from the conspiracy.
In the plea, Verduzco admitted involvement from April to June 2010, admitted renting the rooms and introducing Edgar to Mondragon, but claimed he did not initially realize the introduction was drug-related; he argued he accepted responsibility but the court disagreed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Acceptance of responsibility reduction	Verduzco argued for a 2-point reduction.	Government argued no reduction due to obstruction and evasiveness.	District court did not clearly err; no 2-point reduction to accept responsibility.
Managerial role enhancement	Verduzco argued he was not a leader or organizer.	Government argued he was at least a manager with control over others.	Court affirmed a 3-level enhancement under § 3B1.1(b) for managerial role.
Substantive reasonableness of sentence	Verduzco claimed inequality with co-defendant and argued disparity undermined legitimacy.	Government argued 3553(a)(6) concerns national disparities, not intra-co-defendant disparities.	Sentence within guidelines and substantively reasonable; affirmed.

United States v. Genschow, 645 F.3d 803 (6th Cir. 2011) (standard for reviewing acceptance of responsibility in light of obstruction)
United States v. Morrison, 983 F.2d 730 (6th Cir. 1993) (deference to district court on acceptance of responsibility)
United States v. Washington, 715 F.3d 975 (6th Cir. 2013) (standard for 3B1.1(a)-(c) analysis and deference to factual findings)
United States v. Studabaker, 578 F.3d 423 (6th Cir. 2009) (abuse of discretion in sentencing under §3553(a) variance context)
United States v. Simmons, 501 F.3d 620 (6th Cir. 2007) (3553(a)(6) considerations and national disparity guidance)