“We review for clear error the district court’s factual findings
underlying the imposition of a sentencing enhancement based on the defendant’s role
-5-
in the offense.” United States v. Rosas, 486 F.3d 374, 376 (8th Cir. 2007) (citation
omitted). Under U.S.S.G. § 3B1.1(c), “f the defendant was an organizer, leader,
manager, or supervisor in any criminal activity [not involving five or more
participants], increase by 2 levels.” The terms “organizer,” “leader,” “manager,” and
“supervisor” are to be construed broadly. Rosas, 486 F.3d at 376; United States v.
Willis, 433 F.3d 634, 636 (8th Cir. 2006). In determining whether a defendant had
a managerial or supervisory role in an offense, application note 4 to U.S.S.G. § 3B1.1
directs the district court to consider such factors as:
the exercise of decision making authority, the nature of participation in
the commission of the offense, the recruitment of accomplices, the
claimed right to a larger share of the fruits of the crime, the degree of
participation in planning or organizing the offense, the nature and scope
of the illegal activity, and the degree of control and authority exercised
over others.
