Whether a defendant must have exercised some direction or supervision over a subordinate participant in a criminal activity to qualify for a sentencing enhancement under U.S.S.G. § 3B1.1 as a 'manager or supervisor'

QUESTION PRESENTED 1. U.S.S.G. § 3B1.1 provides a sentencing enhancement for a defendant’s status as a “manager or supervisor” of certain criminal activity. Under the Application Notes, “the defendant must have been the organizer, leader, manager, or supervisor of one or more other participants” to apply the enhancement. (emphasis added). Under Fifth Circuit precedent, a defendant’s management of a criminal activity’s assets is sufficient to qualify the defendant for the “manager or supervisor” enhancement. Must a defendant have exercised some direction or supervision over a subordinate participant in a criminal activity to give rise to the enhancement? i II. PARTIES The