Can a defendant be found to have been an "organizer, leader, or supervisor" in criminal activity?

The Guidelines allow for a two-level "organizer" enhancement "[i]f the defendant was an organizer, leader, manager, or supervisor in any criminal activity" involving fewer than five "participants," provided that the criminal activity was not "extensive." U.S.S.G. 3B1.1(c) (2015). "A participant is a person who is criminally responsible for the commission of the offense, but need not have been convicted. A person who is not criminally responsible for the commission of the offense ... is not a participant." Id. cmt. n.1. In order to impose the enhancement, there must be a "showing that the defendant had control over other[ ]" participants or "organiz[ed] other[ ] [participants] for the purpose of carrying out" the charged crimes. Whitney , 673 F.3d at 975 (internal quotation marks omitted). A defendant "organizes" other participants if he has "the necessary influence and ability to coordinate the[ir] behavior ... so as to achieve the desired criminal result[s]." United States v. Doe , 778 F.3d 814, 826 (9th Cir. 2015) ; see also United States v. Avila , 95 F.3d 887, 890 (9th Cir. 1996) (stating that "some degree of control or organizational authority over others is required" in order for a 3B1.1 enhancement to be proper (internal quotation marks omitted) ). Mere facilitation of criminal activity is not sufficient to support the enhancement. Doe , 778 F.3d at 825. Nor is it sufficient for a defendant to have organized property or activitiesthe defendant must have organized participants . Id. at 824 n.4.