United States v. Pizarro-Berrios

          United States Court of Appeals
                     For the First Circuit


No. 04-2062

                    UNITED STATES OF AMERICA,

                            Appellee,

                               v.

                      ROY PIZARRO-BERRÍOS,

                      Defendant, Appellant.



          APPEAL FROM THE UNITED STATES DISTRICT COURT
                 FOR THE DISTRICT OF PUERTO RICO

         [Hon. Héctor M. Laffitte, U.S. District Judge]


                             Before

                      Boudin, Chief Judge,
              Torruella and Selya, Circuit Judges.


     Jorge L. Armenteros-Chervoni, for appellant.
     Germán A. Rieckehoff, Assistant United States Attorney, with
whom Nelson Pérez-Sosa, Assistant United States Attorney, and H.S.
García, United States Attorney, were on brief, for appellee.



                           May 5, 2006
              TORRUELLA,     Circuit    Judge.       Defendant-Appellant       Roy

Pizarro-Berríos ("Pizarro") pled guilty pursuant to a straight plea

(i.e., without a plea agreement) to conspiracy to commit credit

card, bank fraud, and conspiracy to launder money. He now appeals,

arguing      that    his   plea   was   not   knowing     and    intelligent    and

challenging his sentence.          We affirm in part, vacate in part, and

remand to the district court.

                                         I.

              Pizarro participated in a conspiracy involving the use of

counterfeit credit cards, forged checks, and false identification

documents to purchase merchandise from various businesses.                     The

merchandise was used either for the conspirators' benefit or

resold, with the earnings being distributed to members of the

conspiracy. The conspiracy ran from December 2002 through November

2003.     Pizarro's role in the conspiracy was to make purchases at

local businesses using the counterfeit credit cards.1

              In April 2003, Pizarro was arrested and put in state

custody after attempting to make a purchase at a supermarket in the

town of Canóvanas, Puerto Rico, using a forged check.                While being

held    in   state    custody,    Pizarro     gave   an   oral    statement    (the




1
    A more detailed discussion of the various aspects of the
underlying conspiracy is not necessary for a resolution of this
case.

                                        -2-
"confession")2 to Agent Israel Santiago-Monserrate ("Santiago") of

the Puerto Rico Police Department, discussing the details of the

conspiracy and his involvement in it.                      Santiago transcribed the

confession       and    Pizarro       signed     the    document.          Pizarro    was

incarcerated in state prison on July 7, 2003.                     On August 21, 2003,

Pizarro       entered   a   guilty     plea    to    the    state    charges   and    was

sentenced to two years in prison.

               Meanwhile,      the    other    conspirators         were   arrested    by

federal authorities.           On December 3, 2003, Pizarro was released

from    state     prison    pursuant      to     a   writ    of     habeas   corpus    ad

prosequendum       so   that    he     could   face     federal      charges   for    his

involvement in the conspiracy. On December 8, a federal grand jury

returned an indictment against the members of the conspiracy.

Counsel was appointed for Pizarro on December 10.                      On January 28,

2004,     a    twelve-count          superseding       indictment      issued.        The

superseding indictment charged Pizarro with conspiracy to commit

credit card fraud, in violation of 18 U.S.C. §§ 371, 1029(a)

("Count One"); bank fraud, in violation of 18 U.S.C. §§ 2, 1344

("Count Two"); conspiracy to launder money, in violation of 18

U.S.C. § 1956(a)(1) and (h) ("Count Three"); and identification

fraud, in violation of 18 U.S.C. § 1028(a)(4) ("Count Nine").



2
   The parties argue about whether the statement was a confession,
a sworn statement, or simply a statement. For the sake of clarity,
we will refer to it as a "confession," as we will also be
discussing other statements Pizarro made.

                                           -3-
           According to the government, Pizarro spoke with federal

agents prior to his federal indictment and indicated that he wanted

to cooperate with the government. Some of these conversations were

summarized in what the FBI calls 302 forms.3           The government

eventually offered Pizarro a plea agreement, which he decided not

to take after consulting with his counsel.           According to the

government, the Assistant United States Attorney ("AUSA") handling

the case told Pizarro's counsel that none of Pizarro's statements

summarized in the 302 forms would be used at trial.

           On February 24, 2004, Pizarro filed a motion for change

of plea.   At a change of plea hearing held before the district

court on March 1, 2004, Pizarro entered a straight guilty plea to

Counts One through Three.    Count Nine was dismissed.4       Pizarro's

Presentence Report ("PSR") assigned him a base offense level of 6.

After   relevant   enhancements   and   reductions   were   calculated,

Pizarro's total offense level was 26.5      Combined with a Criminal


3
    302 forms are what the FBI calls reports its agents make
summarizing interviews with witnesses or suspects.
4
    Count Nine charged Pizarro with actions that occurred on
July 21, 2003. However, as Pizarro was incarcerated at that time,
the government conceded that it had misidentified Pizarro as to
Count Nine. The district court therefore dismissed the count at
the change of plea hearing.
5
   The PSR recommended a fourteen-level enhancement under U.S.S.G.
§ 2B1.1(b)(1)(H) because the offenses involved a loss in excess of
$400,000; a two-level enhancement under U.S.S.G. § 2B1.1(b)(2)(A)
because the offenses involved more than ten but fewer than fifty
victims; a two-level enhancement under U.S.S.G. § 2B1.1(b)(3)
because the offenses involved a theft from the person of another;

                                  -4-
History Category of II, the applicable Guidelines range was 70-87

months' imprisonment.

           The PSR referenced the confession Pizarro had provided to

Agent Santiago, as well as the statements found in the 302 forms.

Upon reading the PSR, Pizarro's counsel called the Probation

Officer,   Andrea   Cribben   ("Cribben").    Cribben   told   Pizarro's

counsel that she had received the confession from the case agent.

According to Pizarro, his counsel also contacted AUSA Juan Milanés,

who said that he was unaware of the existence of the confession and

that he had not provided any 302 forms because he did not have to

provide them until trial.      On June 4, 2004, the government faxed

the 302 forms to Pizarro's counsel, and on June 8, the government

faxed the confession.

           On June 9, 2004, Pizarro filed a motion arguing that the

government had violated Rule 16 of the Federal Rules of Criminal

Procedure6 and Brady v. Maryland, 373 U.S. 83 (1963), because it

had not provided Pizarro with either the confession or the FBI 302

forms before Pizarro pled guilty.       Although Pizarro stated in the

motion that the government's actions called into question the


a two-level enhancement under U.S.S.G. § 2B1.1(b)(9) because the
offenses involved the use of sophisticated means; a two-level
enhancement under U.S.S.G. § 2B1.1(b)(10) because the offenses
involved the possession and use of device-making equipment; and a
two-level reduction under U.S.S.G. § 3E1.1(a) for acceptance of
responsibility.
6
  Rule 16 details the government's obligations to provide certain
documents to the defendant.

                                  -5-
voluntariness and intelligence of his guilty plea, he did not ask

that he be allowed to withdraw his plea; rather, he asked that the

district    court     adopt   his   interpretation     of   the   Sentencing

Guidelines.

            The government filed an opposition to Pizarro's motion on

June 16, 2004, stating that it never intended to use the 302 forms

at trial and therefore did not have to disclose them under Rule

16(a)(1)(A).    The government also stated that the case agent did

not   receive   the    confession   until   May   4,   2004,   after     he   had

contacted state police to gather documents to prepare the case for

presentation.    As soon as the case agent received the confession,

he forwarded it to Cribben, who used it in the PSR.            The agent also

sent the document -- which was in the Spanish language -- to a

translator and forwarded a translated copy to the U.S. Attorney's

Office on June 7.        The confession was then faxed to Pizarro's

counsel the following day. According to the government, therefore,

no one involved in the case either knew or could have known of the

confession's existence prior to May 4, 2004, meaning that the

confession could not have been given to Pizarro before he pled

guilty on March 1, 2004.

            Pizarro was sentenced on July 1, 2004. At the sentencing

hearing, the district court denied Pizarro's motion regarding the

alleged    discovery    violations.     The   court    accepted    the    PSR's

calculations, but gave Pizarro a three-level (instead of a two-


                                      -6-
level) reduction for acceptance of responsibility, which resulted

in a Guidelines range of 63-78 months' imprisonment.          The district

court sentenced Pizarro to 70 months' imprisonment as to Counts Two

and Three and 60 months' imprisonment as to Count One, to be served

concurrently with each other and the state sentence.7         However, in

its written judgment, the court stated that Pizarro's federal

prison term would run consecutively to his state sentence. Pizarro

now appeals, arguing that his plea was not knowing and intelligent

because the government failed to disclose the confession or the 302

forms; that he should be re-sentenced pursuant to United States v.

Booker, 543 U.S. 220 (2005); that his sentence included some

improperly applied enhancements; and that the written judgment

should be corrected so that Pizarro's federal prison term runs

concurrently with his state prison term, in accordance with the

district court's oral pronouncement of sentence.

                                  II.

          A.   Rule 16 Violations and Withdrawal of Plea

          We   have   stated   that   a   "district   court    may   allow

withdrawal [of a guilty plea] for 'a fair and just reason.'"

United States v. Padilla-Galarza, 351 F.3d 594, 597 (1st Cir. 2003)

(quoting Fed. R. Crim. P. 11(d)(2)(B)). Among the relevant factors

a court should consider are



7
   The court also sentenced Pizarro to three years of supervised
release, a $1000 fine, and a $300 mandatory monetary assessment.

                                  -7-
           whether a plea was voluntary, intelligent,
           knowing and complied with Rule 11; the force
           of the reasons offered by the defendant;
           whether there is a serious claim of actual
           innocence; the timing of the motion; and any
           countervailing prejudice to the government if
           the defendant is allowed to withdraw his plea.

Id.

           Pizarro appears to argue that his guilty plea was not

knowing and intelligent because of failures of the prosecutor to

disclose (allegedly in violation of Rule 16) both a confession and

various   statements   given   by   Pizarro.   The   supposed   Rule   16

violations were raised in the district court but not as a reason

for withdrawing the plea.      So far as we can tell, Pizarro has not

sought to withdraw his plea either in the district court or his

brief to this Court.

           Further, Pizarro has never explained why the disclosure

of his prior confession or statements would have caused him not to

plead guilty.   If anything, disclosure would seem rather to have

encouraged a guilty plea.      Of course, if Pizarro were asserting

that the government had withheld exculpatory evidence, this would

be quite a different matter, but there is no such suggestion.

           About the best we can make out from the brief is that

Pizarro is not interested in a withdrawal of plea at all but may be

pressing the following conjecture: that if the government had

turned over the confession and other statements at an earlier

stage, counsel might have been able to persuade his client to


                                    -8-
accept an earlier and better plea offer from the government.                      But

this argument, obviously resting on considerable conjecture, is not

itself expressly developed in Pizarro's brief in this court or

supported with any precedent for such a use of Rule 16.

               As it happens, it is uncontested that the federal agents

did not know about the confession until well after the plea.                       As

for the 302 forms, Pizarro makes no claim that at the time he pled

guilty he was ignorant of the fact that he had made statements to

the FBI agents during various interviews.                   There is an argument

that the forms should have been disclosed based on Rule 16 language

not cited by the government, but we have no reason to resolve the

matter.    Pizarro has waived any argument that he should have been

permitted to withdraw his guilty plea by not seeking to have the

plea   withdrawn       before     the   district    court    and   not   making   any

developed argument in favor of such relief on appeal.

               B.    Sentencing

                        1.    Booker

               In his initial brief, filed after the Supreme Court's

decision in United States v. Booker, 543 U.S. 220 (2005), and our

decision in United States v. Antonakopoulos, 399 F.3d 68 (1st Cir.

2005), Pizarro argued that his Sixth Amendment rights were violated

because the district court sentenced him based on facts that were

not    found    by    the    jury.      Pizarro    never    mentioned    Booker   (he

mentioned Apprendi v. New Jersey, 530 U.S. 466 (2000), and Blakely


                                          -9-
v.   Washington,     542    U.S.   296    (2004)),   never   claimed   that   he

preserved a Booker error under Antonakopoulos, and never addressed

the likelihood that he would receive a more lenient sentence on

remand.    Further, after filing his initial brief, Pizarro never

sought leave to file any supplemental materials to make the above

arguments.    Instead, at oral argument, which occurred over a year

after Pizarro filed his initial appellate brief, Pizarro for the

first time argued that he had preserved Booker error.

           We have consistently held that, except in extraordinary

circumstances, arguments not raised in a party's initial brief and

instead raised for the first time at oral argument are considered

waived.    See, e.g., Piazza v. Aponte Roque, 909 F.2d 35, 37 (1st

Cir. 1990).        We will therefore not consider Pizarro's arguments

made for the first time at oral argument and will hold him to what

he argued in his brief.

           In his brief, Pizarro argued that the district court

violated     his    Sixth   Amendment      rights    by   applying   sentencing

enhancements based on facts not found by the jury.             We have already

considered and rejected this argument on numerous occasions, and we

reject it again in this case.            See Antonakopoulos, 399 F.3d at 75

("The [Booker] error is not that a judge (by a preponderance of the

evidence) determined facts under the Guidelines which increased a

sentence beyond that authorized by the jury verdict or an admission

by the defendant; the error is only that the judge did so in a


                                         -10-
mandatory Guidelines system.").           We therefore reject Pizarro's

request that he be re-sentenced under Booker.8

                     2.   Amount of Loss Attributable to Pizarro

          Pizarro also argues that the district court erred in

finding him responsible for over $400,000 in losses, which resulted

in a fourteen-level enhancement. "We review the district court's

interpretation and application of the Guidelines de novo and its

factual findings for clear error."         United States v. Bailey, 405

F.3d 102, 113 (1st Cir. 2005) (internal quotation marks omitted).

Although it is not entirely clear from Pizarro's brief, it appears

that he is making two arguments regarding the imposition of the

enhancement:   (1)    the    district   court   erred   by   automatically

attributing to him the amount of loss charged in Count Two of the

indictment simply because he pled guilty to that count,9 and (2)

that there was insufficient evidence in the record to show that he



8
   In his brief, Pizarro mentions in passing that several of the
enhancements found by the district court were inapplicable to his
case.    However, with two exceptions, discussed infra, these
arguments are made in such a perfunctory manner, buried within
Pizarro's discussion of the constitutionality of his sentence, that
we deem them waived. See United States v. Zannino, 895 F.2d 1, 17
(1st Cir. 1990) (stating that "issues adverted to in a perfunctory
manner, unaccompanied by some effort at developed argumentation,
are deemed waived").
9
   Pizarro actually argues that the district court found that he
was responsible for the totality of the scheme. This is incorrect.
The evidence at sentencing was that the actual loss caused by the
scheme was over $600,000, and the intended loss was over $1.5
million. The district court found that Pizarro was responsible for
over $400,000 in losses.

                                   -11-
was responsible for over $400,000 in losses.           We deal with each in

turn.

          At   sentencing,   a   defendant    in   a   jointly   undertaken

criminal activity is liable for the harm resulting from acts

directly attributable to him and for the harm resulting from the

reasonably foreseeable acts of others taken in furtherance of the

jointly undertaken criminal activity.        See U.S.S.G. § 1B1.3(a)(1),

(3).    However, the fact that a defendant has pled guilty to

involvement in a jointly undertaken criminal activity does not

automatically mean that the defendant is responsible for all the

losses caused by the jointly undertaken criminal activity.              In

United States v. Colón-Solís, 354 F.3d 101, 102 (1st Cir. 2004),

the defendant entered a straight guilty plea to a conspiracy

involving more than five kilograms of cocaine.10 At sentencing, the


10
    Colón-Solís involved a guilty plea to a conspiracy count,
whereas the instant case involves a guilty plea to a substantive
count (bank fraud). However, we do not think the analysis changes.
The reason has to do with the bank fraud statute, 18 U.S.C. § 1344,
and the relevant guideline, U.S.S.G. § 1B1.3.

     18 U.S.C. § 1344 defines bank fraud as "a scheme or artifice."
Under U.S.S.G. § 1B1.3(a)(1), a defendant is liable for all acts
directly attributable to him and "in the case of a jointly
undertaken criminal activity (a criminal plan, scheme, endeavor, or
enterprise . . . whether or not charged as a conspiracy), all
reasonably foreseeable acts and omissions of others in furtherance
of the jointly undertaken criminal activity." U.S.S.G. § 1B1.3(a)
(1)(B) (emphasis added). In accordance with the statute, Count Two
charged Pizarro and others with a scheme and artifice to defraud
certain financial institutions. Thus, Count Two qualifies as a
"jointly undertaken criminal activity" for purposes of U.S.S.G.
§ 1B1.3. No one has argued that $400,000 in losses resulted from
acts directly attributable to Pizarro. Therefore, in determining

                                  -12-
district court found that the defendant was responsible for five or

more kilograms of cocaine, based solely on the defendant's plea.

Id.   We found that "automatically attributing to the [defendant]

the full amount of drugs charged in the indictment and attributed

to the conspiracy as a whole" was error.        Id. at 103.   We therefore

vacated the sentence, stating that, in the drug conspiracy context,

"the court is required to make an individualized finding as to drug

amounts attributable to, or foreseeable by, that defendant."          Id.

In subsequent cases, we have applied Colón-Solís to fraud cases.

See United States v. Rodríguez-González, 433 F.3d 165, 168 (1st

Cir. 2005).      It is therefore clear that, in cases involving a

jointly undertaken criminal activity, a district court must make an

individualized     determination    regarding     the   amount   of   loss

attributable to, or reasonably foreseeable by, a defendant, and may

not rely solely on what was charged in the jointly undertaken

criminal activity count of an indictment, even if the defendant

entered a guilty plea.

          We are initially troubled by this case because it appears

that the district court based its finding at least in part on the

fact that Pizarro pled guilty to Count Two, which alleged his

involvement in a scheme to defraud different financial institutions

of over $400,000.     For example, the court stated that "I notice


the amount of loss attributable to Pizarro, the district court was
required to determine which acts taken by others in furtherance of
the scheme were reasonably foreseeable to Pizarro.

                                   -13-
that the defendant pled guilty to Count 2 which alleged that the

loss was in excess of $400,000.      So why are we wasting time?        He

admitted it.    That's it.   It is the same as if he had gone to trial

and was found guilty as to that amount."        However, elsewhere the

court indicated that it had to make a finding as to the amount

reasonably foreseeable to Pizarro based on the evidence as it

applied to Pizarro.      For example, the court stated: "I told you

that I have to find what is the reasonable [sic] foreseeable amount

of the harm, and that's what we are doing here."         The court also

stated that "[t]he fact is that the intended loss that it is

reasonably foreseeable, all the machines, all of this sophisticated

means, then that's what I have to decide, what was reasonably

foreseeable to him."     (Emphasis added).11

           Having reviewed the record, we believe that the district

court made its finding that Pizarro was responsible for $400,000 in

losses   for   two   reasons:   1)   the   evidence   presented   by   the

government, and 2) the fact that Pizarro had pled guilty to a

scheme involving over $400,000.      The first reason is permissible



11
   We note that the government stated several times that the issue
before the court was whether the losses caused by his others in the
scheme were reasonably foreseeable to Pizarro.       While this is
obviously not conclusive on the reasoning of the district court, we
find it relevant.    If, for example, the government had simply
argued that, because Pizarro pled guilty to Count Two, he was
responsible for $400,000 in losses, that would make it more
probable that the district court had simply attributed the amount
of loss in the indictment to Pizarro without an individualized
determination.

                                  -14-
but the second is an error of law under our precedent.          This

conclusion is borne out by the court's pronouncement of sentence:

          As the offense involved a loss in excess of
          $400,000, I do find that in this case, there
          has been evidence that the loss exceeded
          $400,000, and also I find that the defendant
          pled guilty to the specific amount as charged
          in Count 2, that is bank fraud in excess of
          $400,000, so that's why the Court finds the
          offense involved in excess of $400,000 . . . .

(Emphasis added).   We therefore conclude that the district court's

decision to find Pizarro responsible for over $400,000 in losses

was based in part on an error of law.

          However, that does not mean that we must automatically

remand for re-sentencing.   In Colón-Solís, our decision to remand

was based on the fact that the district court's sole foundation for

finding the defendant responsible for greater than five kilograms

of cocaine was an error of law: that the drug amount charged in the

indictment and attributed to the conspiracy was automatically

attributable to the defendant.    354 F.3d at 102-03.   We also noted

that the record was barren of any evidence as to the drug amounts

directly attributable to, or foreseeable by, the defendant. Id. at

103.   The instant case presents a different situation, as the

district court's decision is not based solely on an error of law.

If there is enough evidence to support the alternative explanation

for the court's finding, the error would be harmless and there

would be no reason to remand to the district court when the result

will be the same.    We therefore turn to whether there is enough

                                 -15-
evidence to show that Pizarro was responsible for $400,000 in

losses.   We conclude that there is.

            As we noted above, a defendant in a jointly undertaken

criminal activity is liable for all losses directly attributable to

him and for all losses resulting from reasonably foreseeable acts

committed by others in furtherance of the jointly undertaken

criminal activity.    In the instant case, it is undisputed that the

amount of loss directly attributable to Pizarro was around $21,000,

and that the amount of actual loss attributable to the entire

scheme was over $600,000.     The issue, then, is whether Pizarro

could have reasonably foreseen the losses caused by others involved

in the scheme such that he should be held responsible for $400,000

in losses.

            We have stated that, in making the above determination,

a court must first "determine what acts and omissions of others

were in furtherance of the defendant's jointly undertaken criminal

activity.    This task requires the court to ascertain what activity

fell within the scope of the specific conduct and objectives

embraced by the defendant's agreement."        United States v. LaCroix,

28 F.3d 223, 227 (1st Cir. 1994).         The court must then "determine

to what extent others' acts and omissions . . . would have been

foreseeable by a reasonable person in defendant's shoes at the time

of his or her agreement."    Id.




                                   -16-
            The acts of Pizarro's co-schemers were within the scope

of Pizarro's agreement.      Pizarro argues that he only had an

agreement with the leader of the scheme, Angel Lacén-de Jesús

("Lacén"), to make purchases.     However, the evidence belies this

argument.     Under the Guidelines, "the court may consider any

explicit agreement or implicit agreement fairly inferred from the

conduct of the defendant and others."    U.S.S.G. § 1B1.3, comment.

(n.2).    Here, the evidence shows that Pizarro implicitly agreed to

be a part of the entire scheme.     Pizarro was part of the scheme

from its inception and knew the leaders of the scheme well.      He

grew up with one of the leaders, Lacén, and also served as his

bodyguard before and up to the point that the scheme began.

Pizarro admitted that he was paid $200 a day to guard Lacén "while

he would do his work, which was the counterfeiting of credit

cards."    Thus, even before he joined, Pizarro knew what Lacén was

doing and planning.    Pizarro also admitted that he knew the other

leader of the scheme, Eric Adorno-Rosario ("Adorno"), and knew that

Adorno and Lacén were partners in the counterfeit credit card

operation. He also admitted that, after serving as a bodyguard for

Lacén, he became a purchaser, "which is the person who goes

shopping with the cards that [Lacén] would make and program."

            This is not a case where a defendant agrees to make a

one-time transaction for a scheme and gets caught.    Here, Pizarro

stated that he was paid $100-$500 per day and that he worked a few


                                 -17-
days a week.        There was also evidence that others accompanied

Pizarro to the stores, so he knew that others were involved in the

scheme.   Given all of this evidence, we find that the acts of

others in furtherance of the scheme were within the scope of an

implicit agreement that Pizarro made.

          We now turn our attention to what losses were reasonably

foreseeable    to    Pizarro.    Given   the   evidence   presented   at

sentencing, we conclude that the district court did not err in

finding that $400,000 was reasonably foreseeable to Pizarro.          We

base this finding on Pizarro's knowledge of the inner details of

the scheme.

          In LaCroix, we stated that:

          foreseeability may be established . . . by a
          defendant's knowledge of the nature and extent
          of    a   conspiracy    in    which   he    is
          involved . . . . It is both good law and good
          logic that a defendant's awareness of the
          inner workings of a conspiracy in which he is
          participating is germane to, and often highly
          probative of, accomplice attribution . . . .
          Such knowledge frequently will suffice to
          prove the defendant's ability to foresee the
          acts of coconspirators.

28 F.3d at 229.      The instant case presents an example of what we

discussed in LaCroix.       As we noted above, Pizarro was with the

scheme from the beginning.      He knew the leaders of the scheme and

the details of their roles in the scheme.       He also knew others in

the scheme.    Further, Pizarro knew details about how the leaders

made the counterfeit credit cards, was able to give details about


                                  -18-
how the programs used in making the cards were accessed, and knew

where the leaders stored their computers. He knew how the machines

worked, and also knew that the leaders made not just counterfeit

credit cards, but also counterfeit checks and fake licenses.                He

also knew that the leaders got their computers from a man named

Francisco, and stated that Francisco was able to obtain equipment

"to commit all types of fraud."               Further, in his role as a

purchaser, Pizarro knew exactly why he was making the purchases.

He admitted that every few days he would change businesses where he

made   purchases   in    order   to     avoid   being   identified    by    an

establishment's personnel.        In sum, while his actual acts in

furtherance of the scheme only involved bodyguard duties and making

purchases, Pizarro was intimately acquainted with the details of

the scheme.   We therefore hold that the district court correctly

found that the loss of $400,000 was reasonably foreseeable by

Pizarro.

           Pizarro attempts to get around these difficulties by

making two arguments: (1) that his role was minor and that he only

participated in exchange for drugs, and (2) that he did not

participate in the scheme once he went to jail in July 2003.                We

reject both of these arguments.              First, it is settled that a

district   court   may   correctly     attribute    "the   entire    loss   to

appellant" even considering "the fact that he may have played only

a supporting role."      LaCroix, 28 F.3d at 231.       Here, the fact that


                                      -19-
Pizarro only acted in a supporting role in no way means that the

losses stemming from the jointly undertaken criminal activity were

not reasonably foreseeable to him, especially given his knowledge

of the inner workings of the scheme. Further, although Pizarro was

allegedly given drugs in exchange for his services, there was also

evidence that he was paid between $100-$500 per day and worked two

to three days per week.        In other words, he was not simply making

purchases in exchange for drugs.

              Second, Pizarro has presented absolutely no evidence that

he ever withdrew from the scheme.         We have stated that "in order to

withdraw from a conspiracy, a conspirator must act affirmatively

either   to    defeat   or   disavow    the   purposes   of   the   conspiracy.

Typically, that requires either a full confession to authorities or

a communication by the accused to his co-conspirators that he has

abandoned the enterprise and its goals."           United States v. Piper,

298 F.3d 47, 53 (1st Cir.              2002); see also United States v.

Robinson, 390 F.3d 853, 882 (6th Cir. 2004) (stating that, even

assuming that after his arrest the defendant was no longer an

active participant in the conspiracy, "he is nonetheless presumed

to be a continuing member, and is chargeable for the subsequent

acts of co-conspirators, so long [as] the conspiracy was ongoing

and [the defendant] did not establish his affirmative withdrawal




                                       -20-
from the conspiracy").12        At sentencing, the prosecutor noted that

Pizarro   --   although    he    initially     gave   a   statement   to   the

Commonwealth agent who arrested him            -- had not provided a "full

confession" and had been "obstinate with respect to his culpability

in this case."    In conclusion, Pizarro has not provided evidence

that he gave a full confession or informed others involved in the

scheme that he was abandoning the scheme, and the fact that he was

in jail does not in and of itself mean that he withdrew from the

scheme.   See, e.g., Robinson, 390 F.3d at 882 (stating that "a

defendant's arrest . . . does not qualify as an affirmative,

volitional act of withdrawal [from a conspiracy]"); United States

v. Melton, 131 F.3d 1400, 1405 (10th Cir. 1997) (stating that a

defendant's    arrest,    by    itself,   is   insufficient   to   constitute

withdrawal from a conspiracy).

           We find that the district court did not commit clear

error in its finding that there was enough evidence to find Pizarro

responsible for over $400,000 in losses.              We base this finding

primarily on Pizarro's relationship with the leaders of the scheme

and his knowledge of various intimate details of the scheme.                We

therefore affirm the district court's decision to apply a fourteen-

level enhancement to Pizarro's sentence.


12
   As we noted above in footnote 10, Count Two was not a conspiracy
count. Nevertheless, since Count Two alleged Pizarro's involvement
in a scheme, we think the analysis regarding withdrawal from a
conspiracy applies with equal force to withdrawal from a scheme to
defraud financial institutions.

                                     -21-
                     3.   Theft From The Person of Another Enhancement

           Pizarro has also challenged a two-level enhancement of

his offense level pursuant to U.S.S.G. § 2B1.1(b)(3), which applies

"[i]f the offense involved a theft from the person of another," id.

This challenge is only dubiously preserved, as Pizarro devotes but

half a paragraph to it and performs none of the spadework necessary

to enable us to figure out precisely what is going on.                   But the

enhancement clearly affects Pizarro's sentence, and it is easy to

understand the thrust of what he is arguing once the guideline (and

its accompanying commentary) is consulted.              In light of this, and

to guide the future application of this particular guideline, it is

useful to say something about the issue.

           At first blush, it looks like § 2B1.1(b)(3) does not

apply here at all.        Even if one could construe the text of the

guideline as ambiguous, the commentary to the guideline makes it

clear that the guideline is intended to apply to physical takings,

not to abstract forms of theft that take place far from the victim,

like credit card fraud.      The application note defines "theft from

the person of another" as "theft, without the use of force, of

property that was being held by another person or was within arms'

reach"   (emphasis    added),   and    it    provides    as   examples    "pick-

pocketing and non-forcible purse-snatching, such as the theft of a

purse from a shopping cart."      Id., comment. (n.1).         The background

note explains that such theft "receives an enhanced sentence


                                      -22-
because of the increased risk of physical injury" that inheres in

such activity.        Id., comment. (backg'd).

               The case law on this particular guideline -- none of

which is cited by Pizarro or the government -- is consistent with

the    view    that    the    guideline     targets   physical      and   therefore

potentially violent (even if non-forcible) forms of theft.                       See

United States v. Rizzo, 349 F.3d 94, 98, 100 (2d Cir. 2003); United

States v. Londono, 285 F.3d 348, 350-51, 353-54 (5th Cir. 2002);

United States v. Jankowski, 194 F.3d 878, 885-86 (8th Cir. 1999).

To the extent Pizarro's PSR recommended this particular enhancement

based upon a contrary reading of § 2B1.1(b)(3), it was fairly

evidently mistaken.

               But the district judge was more discerning in his reading

of the guideline.            Looking at the transcript of the sentencing

hearing, it is apparent that the judge recognized immediately that

some    kind    of    physical    taking     was   required    to    trigger     this

guideline, and said initially that he was "going to eliminate that"

enhancement.         At that point, the AUSA intervened to explain that

victims'       "[credit]     cards   were    being    taken"   as    part   of   the

conspiracy.       Pizarro's lawyer did not object (nor had he objected

to the enhancement in his written objections to the PSR), and the

district court included the enhancement.

               We have some basis for conjecturing that the AUSA,

doubtless innocently, was referring not to any physical theft of


                                          -23-
credit cards from the victims, but to the practice by which co-

conspirators, employed at retail establishments, would take credit

cards handed over voluntarily by customers (to pay for goods or

services) and surreptitiously swipe them through machines designed

to "steal" sufficient information from the cards to permit them to

be copied.   The cards would then be returned to the owners; the

only theft was of the information stored on the credit cards'

magnetic stripes.     This was not made clear to the judge at the

sentencing hearing.

          If that is all that the AUSA meant when he said "[credit]

cards were being taken," then that form of theft falls just as much

outside the guideline as the form of credit card fraud practiced by

Pizarro himself in his role in the conspiracy (using forged credit

cards to purchase goods).   Such theft involves no physical taking

and no appreciable risk of escalating to violence.   We do not know

for certain what the AUSA was referring to at the sentencing

hearing, and therefore under the circumstances we do not know

whether the district court erred when it applied the enhancement.

We are therefore in no position to engage in plain error review

(which, of course, would be all Pizarro is entitled to, since he

failed to raise this objection below).

          Although counsel for Pizarro may have an explanation for

having not pursued the objection below, this may well afford some

basis for an ineffective assistance of counsel claim, given a plain


                                -24-
reading of the guideline commentary and the apparent lack of

evidence that any credit cards were physically stolen.                     But of

course this is a matter that must be raised by a § 2255 attack on

competence of counsel, see 28 U.S.C. § 2255, and a matter we are

not in a position to address, except to say that, although we take

no view on whether ineffective assistance occurred here, it is

promising enough that if a habeas petition is filed, the court

should consider appointing counsel for Pizarro.

            C.    Concurrent vs. Consecutive Sentences

            As we have already noted, in its oral pronouncement of

Pizarro's    sentence,        the   district   court     stated   that   Pizarro's

federal prison term would run concurrently with the sentence he was

serving for state convictions.           Nevertheless, the written judgment

said that the sentences would run consecutively.                  The government

concedes that the case should be remanded so that the written

judgment can be modified to agree with what the district court

stated at the sentencing hearing.              See United States v. Muñiz, 49

F.3d 36, 42 n.5 (1st Cir. 1995) ("Where, as in this case, the

district court's oral expression of its sentencing rationale varies

materially       from   its    subsequent      written     expression    of   that

rationale, appellate courts have tended to honor the former at the

expense of the latter.").            We will therefore remand the case so

that this portion of the sentence may be corrected.




                                        -25-
                               III.

          For the foregoing reasons, we affirm the district court's

decision not to allow Pizarro to withdraw his plea.      We vacate

Pizarro's sentence and remand to the district court so that the

written judgment may be corrected to agree with the oral sentence.

          Affirmed in part, Vacated in part, and Remanded.




                               -26-