Santos

MEMORANDUM *

Rommel Santos challenges the district court’s application of a two-level aggravating role enhancement under U.S.S.G. § 3Bl.l(c). We affirm.

Section 3Bl.l(c) permits the district court to increase a defendant’s offense level by two levels if it finds that the defendant was an “organizer, leader, manager, or supervisor” in the offense. Factors to consider in determining whether the defendant qualifies for an “organizer” enhancement include the nature of his participation in the offense, the extent to which he participated in planning the offense, and whether he recruited accomplices. U.S.S.G. § 3B1.1 cmt. n. 4. A district court’s determination that a defendant was an organizer or leader for the purposes of applying a § 3B1.1 enhancement is reviewed for clear error. United States v. Montano, 250 F.3d 709, 712 (9th Cir.2001).

The district court found that Santos was an “organizer” because he “was involved with recruiting other participants as check cashers” and because he provided the stolen mail to “Cowboy,” who then used it to produce the counterfeit checks. This finding was not clearly erroneous. Santos admitted that he had given the stolen mail to Cowboy to…