United States v. Tyree Bennett, 614 F. App'x 403

Bennett was charged with conspiracy to possess with intent to distribute cocaine (>500g) and marijuana (>100 kg) and pleaded guilty.
While awaiting sentencing, he discussed arranging a third party to "cooperate" with government to secure a §5K1.1/§3553(e) sentence reduction.
Unknown to agents, Bennett planned to pay the cooperator and market a cooperation-for-hire scheme; he sent a nine‑page letter promising payment and instructing secrecy.
The government obtained the letter before sentencing; the district court applied a two‑level obstruction enhancement under U.S.S.G. §3C1.1 and denied a 3‑point acceptance reduction under §3E1.1.
Bennett received a 156‑month sentence and appealed the §3C1.1 enhancement and noted clerical errors in the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §3C1.1 obstruction enhancement applies for arranging/secretly paying a cooperator to influence sentencing	Bennett: His intent to obtain a sentence reduction is not "criminal intent" and his conduct is not listed in Application Note 4	Government/District Court: Bennett willfully attempted to conceal material information from probation and arranged corrupt cooperation; Application Note 4 is non‑exhaustive and Note 3 defines obstruction broadly	Court affirmed: conduct was willful obstruction related to sentencing; enhancement proper under §3C1.1
Whether judgment contains clerical errors requiring correction	Bennett: (raised) errors in judgment language and omitted statutory reference	Government: (court recognized errors)	Court remanded for limited correction of scrivener errors (wrong unit for marijuana and omitted statutory citation)

United States v. Massey, 443 F.3d 814 (11th Cir. 2006) (defines "willfully" in §3C1.1 and standard of review)
United States v. Doe, 661 F.3d 550 (11th Cir. 2011) (obstructive conduct must occur during investigation/prosecution/sentencing; low threshold for materiality)