US v. Steffen: Sreffen was a South Carolina Highway Patrolman who was part of a "large-scale" conspiracy involving the cultivation and distribution of marijuana. He pleaded guilty to a conspiracy charge that carried a five-year mandatory minimum. At sentencing, a main issue was whether Steffen was a "manager of supervisor" of criminal activity, worth of a three-level Guideline enhancement. The district court concluded that he was, because he purchased the land on which the marijuana was grown, transported marijuana in his patrol car, and used the car to follow a coconspirator so he would not be pulled over. The district court imposed the mandatory minimum sentence, 60 months, which was also the bottom of the Guideline range.
On appeal, Steffen challenged the management/supervision enhancement, arguing that the evidence showed he only managed property, not other co-conspirators. The court disagreed, holding that the use of Steffen's patrol car to escort another co-defendant (so as to avoid being stopped) was a "management decision regarding the manner in which another participant in the conspiracy was to conduct the conspiracy's business." Similarly, the enhancement was applicable because Steffen transferred the energy bill at the location where the marijuana was grown to another co-defendant to avoid detection.