United States v. Roshunda Smith, 520 F. App'x 473

Townsend and Smith filed 174 fraudulent income-tax returns, causing IRS refunds of about $450,000.
They used W-2 data from a former Smith employer and misrepresented income and credits for acquaintances and Townsend’s relatives.
Refunds were mailed to Townsend’s address or deposited into her, or co-participants’, bank accounts.
Total intended loss was about $1.5 million; actual loss paid out was roughly $450,000.
Both defendants pled guilty to a single count of conspiracy to defraud the United States; Townsend faced a base offense level of 6 with a 12-level loss enhancement and no role adjustment, Smith faced higher adjustments for loss and supervisory role.
Townsend was categorized as criminal history category III; Smith as category II; advised ranges were 24–30 months for Townsend and 46–57 months for Smith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court adequately address Townsend's mitigation argument?	Townsend argued her minor role warranted below-guidelines treatment.	Townsend's counsel asserted the court failed to address her mitigation contentions.	Court’s rationale supports within-guidelines sentence; no remand needed.
Was Smith's sentence reasonable and properly preserved for appeal?	Smith argues for a potentially non-frivolous appeal challenging his sentence.	Counsel indicated any challenge would be frivolous and moved to withdraw.	Counsel’s Anders motion granted; appeal dismissed.
Did the district court’s explanation show adequate consideration of Townsend's role and mitigation?	Townsend contends she was not a ringleader and had a limited role.	Court emphasized Townsend’s recruitment of others and involvement of her children.	Rationale indicates substantial consideration of Townsend's role within the record.

Rita v. United States, 551 U.S. 338 (2007) (within-Guidelines sentencing presumption; 18 U.S.C. § 3553(a) factors)
United States v. Chapman, 694 F.3d 908 (7th Cir. 2012) (mandates addressing principal mitigation arguments)
United States v. Robertson, 662 F.3d 871 (7th Cir. 2011) (remand when district court omits principal mitigation argument)
United States v. Villegas-Miranda, 579 F.3d 798 (7th Cir. 2009) (remand standard for mitigation discussion)
United States v. Cunningham, 429 F.3d 673 (7th Cir. 2005) (when addressing mitigation, district court need not respond to stock arguments)
Schroeder v. United States, 536 F.3d 746 (7th Cir. 2008) (courts may rely on context if rationale is clear)
Miranda v. United States, 505 F.3d 785 (7th Cir. 2007) (explanation of mitigation consideration and record relevance)
United States v. Isom, 635 F.3d 904 (7th Cir. 2011) (Guidelines calculations must be uncontested to preserve appeal)
United States v. Thornton, 463 F.3d 693 (7th Cir. 2006) (objecting to guideline calculations on appeal; preservation)
United States v. Pape, 601 F.3d 743 (7th Cir. 2010) (presumption of reasonableness for within-Guidelines sentences)
McIlrath v. United States, 512 F.3d 421 (7th Cir. 2008) (Guidelines address the average offender)