The following excerpt is from U.S. v. Blount, 291 F.3d 201 (2nd Cir. 2002):
Section 3B1.1(b) of the Guidelines requires a three-step increase in offense level if "the defendant was a manager or supervisor (but not an organizer or leader) and the criminal activity involved five or more participants or was otherwise extensive...." Guidelines 3B1.1(b). A defendant may properly be considered a manager or supervisor if he "exercise[d] some degree of control over others involved in the commission of the offense ... or play[ed] a significant role in the decision to recruit or to supervise lower-level participants." Ellerby v. United States, 187 F.3d at 259 (internal quotation marks omitted); see also Guidelines 3B1.1 Application Note 4.
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