United States v. Martha James

MEMORANDUM

Martha James appeals from the district court’s judgment and challenges the 65-month sentence imposed following her guilty-plea conviction for importation of methamphetamine, in violation of 21 U.S.C. §§ 952 , 960. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

James contends that the district court erred in several ways when it denied her a-minor role adjustment. First, James argues that the district court applied the wrong legal standard by ignoring the culpability of others in the smuggling enterprise. There is no evidence in the record that the district court improperly ignored the culpability of other participants. Moreover, contrary to James’s suggestion, the court was not required to compare her conduct to the conduct of hypothetical participants. See United States v. Rosas, 615 F.3d 1058, 1068 (9th Cir.2010).

James also contends that the district court erred by failing to take into account her limited knowledge about the drug operation. The district court properly took into account the totality of the circumstances and did not clearly err by concluding that James failed to meet her burden of proving that she was entitled to a minor role…