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Whether a defendant who took part in a criminal scheme with multiple participants is properly subject to the leader/organizer enhancement at USSG § 3B1.1(a), where the defendant had no control over any other participant and was not the architect who planned and organized the scheme, but who, at the behest of those running the scheme, held himself out as a successful participant that others could emulate?
Question Presented Whether a defendant who took part in a criminal scheme with multiple participants is properly subject to the leader/ organizer enhancement at USSG § 3B1.1 (a), where the defendant had no control over any other participant and was not the architect who planned and organized the scheme, but who, at the behest of those running the scheme, held himself out as a successful participant that others could emulate? i Statement of