United States v. White, 675 F.3d 1106

White was convicted by a jury of assault resulting in serious bodily injury under 18 U.S.C. §§ 2, 1153, 113(a)(6).
Witnesses, including the victim and White's minor son, testified White and her nephew assaulted Campbell at White's home during a party.
The incident occurred at White's residence on the Santee Sioux Indian Reservation after a night at a bar.
Campbell suffered severe facial injuries and long-term vision-related effects from the attack.
White's nephew pled guilty; White's son was acquitted; Saul's charges were dismissed.
The district court varied downward from the advisory Guidelines range and sentenced White to 48 months imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	White argues witnesses were intoxicated or biased, undermining reliability.	White contends the evidence does not prove guilt beyond a reasonable doubt.	Sufficient evidence supports the verdict; appellate court defers to jury credibility.
Obstruction of justice enhancement	White contends there was no perjury that warrants a § 3C1.1 enhancement.	Government argues White testified falsely relative to the charged offense.	Enhancement proper; court accepted perjury finding based on White's and her son's competing testimony.
Minor-participant adjustment	White claims she was a minor participant and entitled to § 3B1.2(b) reduction.	District court found no support for minor-participant reduction and that White was more culpable.	No clear error; no basis for minor-participant adjustment.
Weapon enhancement and downward variance	White asserts the enhancement for use of a dangerous weapon should affect downward variance.	The record supports the dangerous-weapon enhancement; White aided her nephew's attack.	Enhancement applied; its inclusion does not render sentence substantively unreasonable.
Reliance on advisory guidelines	White argues excessive reliance on the advisory Guidelines.	Court properly considered § 3553(a) factors and sua sponte concluded a below-range sentence served purposes.	Court did not abuse discretion in not further reducing below-guideline sentence.

United States v. Claybourne, 415 F.3d 790 (8th Cir. 2005) (jury credibility of witnesses is not ordinarily a basis for reversal)
United States v. Espino, 317 F.3d 788 (8th Cir. 2003) (credibility determinations fall within jury's province)
United States v. McKay, 431 F.3d 1085 (8th Cir. 2005) (improper to reassess witness credibility on appeal)
United States v. Yarrington, 634 F.3d 440 (8th Cir. 2011) (upholding obstruction enhancement where testimony was false on material matter)
United States v. Steele, 550 F.3d 693 (8th Cir. 2008) (tennis shoes as a dangerous weapon question of fact)
United States v. Mitchell, 613 F.3d 862 (8th Cir. 2010) (minor-participant reduction standard)
United States v. McKanry, 628 F.3d 1010 (8th Cir. 2011) (below-guideline sentencing and discretion inquiry)
United States v. Moore, 581 F.3d 681 (8th Cir. 2009) (guidelines below-range sentencing and discretion)