United States v. Steven Morris, 2015 U.S. App. LEXIS 11425

Steven Morris was convicted after a bench trial of conspiracy to distribute ≥500 grams of methamphetamine and conspiracy to launder drug proceeds; district court sentenced him to 360 months (bottom of Guidelines).
Key testimony from cooperating witnesses (Michelle Hendrix, Adrienne Maar, Samantha Worley, Craig Sontheimer) placed repeated drug sales at Morris’s house, described fronting of large quantities, deliveries, and cash collection; district court credited their testimony.
Investigator J.D. Roberts testified there were no reported earnings or IRS filings for Morris (2009–2012) and identified cash expenditures (car purchase, home repairs); no law enforcement observed Morris with drugs, no undercover buys, surveillance, or intercepted communications.
Hendrix and Maar testified to frequent ounce- and pound‑level transactions, Hendrix kept transaction notebooks and delivered proceeds to Morris; witnesses identified Morris’s house (noting a school across the street).
Presentence report recommended a +4 role enhancement (organizer/leader, U.S.S.G. §3B1.1(a)) and a +2 criminal‑livelihood enhancement (U.S.S.G. §2D1.1(b)(15)(E)); district court overruled objections and applied both enhancements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for conspiracy to distribute ≥500g meth	Government: cooperating witnesses’ firsthand accounts and corroboration support conviction	Morris: testimony unbelievable; no direct observation of drugs or proceeds by law enforcement; alias uncertainty	Court: Evidence sufficient — cooperating witness testimony and corroboration upheld conviction
Sufficiency of evidence for money‑laundering conspiracy	Government: cash purchases, lifestyle expenditures, Facebook photos, and transactions show laundering intent	Morris: cash could be from legitimate business; investigation didn’t exclude lawful sources	Court: Evidence supported knowing financial transactions using drug proceeds and intent to further drug trafficking
§3B1.1(a) organizer/leader enhancement	Government: Morris fronted drugs, recruited/directed deliverers, controlled access to house, exercised decision authority	Morris: argued lack of direct control evidence and no law‑enforcement observation	Court: District court did not clearly err — facts supported leader/organizer role and +4 enhancement
§2D1.1(b)(15)(E) criminal‑livelihood enhancement	Government: no reported income, weekly large sales, cash purchases and home/business expenditures show livelihood from drug sales	Morris: challenges role enhancement and asserts possible lawful income sources	Court: Because aggravating role was supported, +2 livelihood enhancement was not clearly erroneous

United States v. Bradley, 643 F.3d 1121 (8th Cir. 2011) (standards for assessing witness credibility and sufficiency challenges)
United States v. Bowie, 618 F.3d 802 (8th Cir. 2010) (bench‑trial sufficiency review follows same standard as jury verdict)
United States v. Huggans, 650 F.3d 1210 (8th Cir. 2011) (upholding verdict if reasonable factfinder could find guilt beyond reasonable doubt)
United States v. Coleman, 525 F.3d 665 (8th Cir. 2008) (verdicts may rest solely on cooperating witness testimony)
United States v. Peeler, 779 F.3d 773 (8th Cir. 2015) (multiple sales of resale quantities can support conspiracy to distribute)
United States v. Hudspeth, 525 F.3d 667 (8th Cir. 2008) (elements of money‑laundering conspiracy under §1956)
United States v. Sherman, 262 F.3d 784 (8th Cir. 2001) (evidence of converting drug cash into assets supports laundering and leadership findings)
United States v. Foxx, 544 F.3d 943 (8th Cir. 2008) (financial transaction evidence can support money‑laundering convictions)
United States v. Thompson, 210 F.3d 855 (8th Cir. 2000) (organizer/leader role need not include direct control; broadly construed)
United States v. Cooper, 767 F.3d 721 (7th Cir. 2014) (decision‑making authority in drug conspiracies supports role enhancement)