United States v. Bryan Darnel Ragsdale -Eastern District of Kentucky at Lexington
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The Sixth Circuit upheld Bryan Ragsdale’s 170-month sentence for methamphetamine and fentanyl distribution. It ruled that the district court properly applied a two-level aggravating-role enhancement under U.S.S.G. § 3B1.1 because Ragsdale managed his co-conspirator during three controlled buys and that the court adequately considered his personal history in selecting a mid-Guidelines sentence.
Circuit Split Identified
Legal Issue
Whether the two-level aggravating-role enhancement under U.S.S.G. § 3B1.1(c) applies when a defendant directs another participant to act as a drug courier on only a single occasion without exercising ongoing control or superiority over that participant.
Circuit Positions
§ 3B1.1(c) enhancement applies when the defendant directs another participant to deliver drugs even once; temporary or one-time supervision is sufficient.
§ 3B1.1(c) enhancement does not apply where the defendant directs a courier on only one occasion and acts as an equal rather than a superior.
Conflict Summary
The Seventh Circuit holds that a defendant who instructs a courier on just one occasion, apparently as an equal rather than a subordinate, is not a manager/leader for purposes of § 3B1.1(c). The Sixth Circuit has expressly rejected that view, ruling that even a one-time or temporary direction of another participant to deliver drugs suffices for the two-level enhancement.