United States v. Precious House, 883 F.3d 720

From Feb–Dec 2013 House ran a scheme using his dealership (Rolling Auto) and a sham business (Xpress Automotives) to obtain auto loans by submitting falsified purchase orders and borrower information.
Co-defendant Crystal Williams prepared fraudulent loan applications for multiple borrowers using vehicle details House supplied; loan checks were directed to Rolling Auto or cashed, and proceeds were split among participants.
House personally participated in 51 loan applications, 36 of which were approved, producing $1.1 million in loan proceeds; House retained about $105,590—the largest share.
A jury convicted House of six counts of bank fraud on March 19, 2015; the PSR recommended a leadership enhancement under U.S.S.G. § 3B1.1(a), and the government sought a § 3B1.1(b) manager/supervisor enhancement.
The district court applied a three-level § 3B1.1(b) enhancement, finding House planned the scheme, used his business as the cover, provided falsified vehicle data, handled and distributed funds, and retained the largest share; it sentenced him to 108 months. House appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3B1.1(b) manager/supervisor enhancement applies	Govt: House helped manage/supervise the scheme through planning, use of his business, coordinating funds, and retaining largest share	House: No hierarchy or direct control over others; roles were equal, so enhancement improper	Affirmed: enhancement proper — House helped manage/supervise the scheme

United States v. Grigsby, 692 F.3d 778 (7th Cir. 2012) (manager/supervisor means someone who helps manage or supervise a criminal scheme)
United States v. Dade, 787 F.3d 1165 (7th Cir. 2015) (§ 3B1.1 requires a commonsense judgment about defendant’s relative role; control is one measure among others)
United States v. Weaver, 716 F.3d 439 (7th Cir. 2013) (Application Note 4 factors may be considered but are not prerequisites)
United States v. Figueroa, 682 F.3d 694 (7th Cir. 2012) (Note 4 factors may be unhelpful for identifying middle managers/supervisors)
United States v. Gracia, 272 F.3d 866 (7th Cir. 2001) (enhancement normally requires some exercise of control over others)