United States v. Sicher

          United States Court of Appeals
                      For the First Circuit

No. 07-2414

                    UNITED STATES OF AMERICA,

                            Appellee,

                                v.

                         KAREN L. SICHER,

                      Defendant, Appellant.


          APPEAL FROM THE UNITED STATES DISTRICT COURT
                FOR THE DISTRICT OF MASSACHUSETTS

          [Hon. Morris E. Lasker, U.S. District Judge]


                              Before

                        Lynch, Chief Judge,
                Boudin and Lipez, Circuit Judges.



     Syrie D. Fried, Office of the Massachusetts Federal Defender,
for appellant.
     Mark T. Quinlivan, Assistant United States Attorney, with whom
Michael J. Sullivan, United States Attorney, and Linda M. Ricci,
Assistant United States Attorney, were on brief, for appellee.



                          August 7, 2009
           LYNCH, Chief Judge.          This sentencing appeal primarily

raises the question of what evidence is sufficient to establish

that the defendant held a position of trust for purposes of

U.S.S.G.   §    3B1.3   to   support   the   imposition     of   a   sentencing

enhancement.

           Defendant Karen Sicher, who was the sole employee of a

surgeon and the charitable foundation for children's medical care

he   started,    pled   guilty   to    ten   counts   of    uttering     forged

securities, in violation of 18 U.S.C. § 513, ten counts of health

care program theft, in violation of 18 U.S.C. § 669, and six counts

of income tax evasion, in violation of 26 U.S.C. § 7201.                    The

district court imposed a sentence of 36 months' imprisonment on

each count to be served concurrently, followed by 36 months of

supervised release, and restitution in the amount of $334,639.

           Sicher challenges her sentence on two grounds.                First,

she contends that the district erred in imposing a two-level

sentencing enhancement for abuse of a position of trust, U.S.S.G.

§ 3B1.3.       That enhancement increased her Guidelines sentencing

range from 24 to 30 months to 30 to 37 months.             Second, she argues

the district court failed to consider evidence of her mental

health, which she claims merits a downward variance.                 Finding no

error, we affirm.




                                       -2-
                                        I.

             The following evidence was part of the record before the

district court at sentencing.        The district court at sentencing is

entitled      to   draw    "fair    inference[s],"          United   States   v.

Tejada-Beltran, 50 F.3d 105, 113 (1st Cir. 1995), from the evidence

before it.1    United States v. Marceau, 554 F.3d, 24 (1st Cir. 2009)

("A sentencing court is entitled to rely on circumstantial evidence

and   draw   plausible     inferences    therefrom."    (internal     citations

omitted)).

             For   ten    years,   Sicher     worked   as    an administrative

assistant and secretary to Dr. David S. Walton, a surgeon in

ophthalmology specializing in children's glaucoma, a leading cause

of blindness for infants and toddlers.           Dr. Walton was a "busy and

focused surgeon" who had a heavy load of clinical duties and

significant teaching responsibilities at Harvard Medical School,

where he was a Professor of Ophthalmology.              He spent long hours

tending to his medical responsibilities.2


      1
          The court is not restricted to drawing only those
inferences compelled by the evidence.       See United States v.
Olivero,552 F.3d 34, 38-39 (1st Cir. 2009) ("If the facts plausibly
support competing inferences, as here, a sentencing court cannot
clearly err in choosing one.").
      2
          Dr. Walton's testimony was that the practice was "special
place" in a unique environment that focused on particularly
"complex and difficult patients."          While ophthalmologists
ordinarily see 50 to 60 patients a day, Dr. Walton saw five to six
patients on a busy day, spending considerable time with each. This
close-knit medical practice had a small roster of patients whom Dr.
Walton treated more intensively. Patients began seeing Dr. Walton

                                        -3-
           Dr. Walton relied heavily upon the defendant, his sole

employee and "trusted representative," to run his medical office

while he focused on these other demands.                  Indeed, Sicher perceived

herself as having essential managerial responsibilities.                    She told

the government in interviews that she took care of Dr. Walton on a

day-to-day basis and that, for example, Dr. Walton did not know how

to use an ATM.        Utilizing her position as his assistant, Sicher

stole at least $150,000 from payments to his medical practice.

           In     addition,   Sicher      played      a    second   role   which    is

particularly significant to the question of whether the enhancement

was correctly applied.           For seven of those ten years, for an

additional monthly payment, she also handled all administrative

tasks for the Children's Glaucoma Foundation ("CGF").                      CGF was a

non-profit organized by Dr. Walton initially and dedicated to

supporting    programs     for     children's      glaucoma      sufferers.        The

organization      raises   money    and   provides         grants   in   support    of

programs     to   increase    awareness      of      children's     glaucoma,      two

university    based    research     studies     on    childhood     glaucoma,      and

support of physician training in the care of affected children.

The record before us does not show how many funds were raised for

CGF, but the records show Sicher stole approximately $193,000 of

those funds.       Many families whose children were treated by Dr.




as newborns, and he continued treating them through their teenage
years.

                                       -4-
Walton also devoted their financial and personal energies to

supporting CGF.

            The foundation had only two functions: fundraising and

distributing the funds it raised through grants.            Only two people

were involved in the day-to-day management of CGF: Dr. Walton and

Sicher.     As said, Dr. Walton spent almost all of his time and

energies in providing       medical treatment to his patients, as well

as fulfilling his academic and teaching responsibilities.                  This

meant that the other responsibilities for CGF, particularly the

management of fundraisers, fell largely on Sicher.

A.          Sicher's Dual Job Responsibilities

            Hired in 1995, Sicher was Dr. Walton's sole employee and

was    responsible   for   managing   his    medical    practice.    Her    job

responsibilities     in    Dr.   Walton's    practice    included   welcoming

patients, scheduling appointments, doing the bookkeeping, accepting

and depositing co-payments and medical reimbursement checks, and

receiving the practice's bank account statements.              While he was

busy    providing    medical     services,   Dr.   Walton   relied   on    the

defendant, his "trusted representative in the office environment,"

to manage all the financial and administrative functions of the

office.    Through her position, she became personally close with

many of the families of Dr. Walton's patients.

            In 1998, upon the founding of CGF, Dr. Walton asked

Sicher to take on all administrative responsibilities for CGF. Her


                                      -5-
formal duties included accepting and depositing donations for CGF,

informing Dr. Walton of any donations, and opening and reviewing

CGF's monthly bank statements.    In practice, Sicher's activities

went well beyond her formal duties.    Her duties were essential to

the management of CGF; she effectively acted as the director of

CGF.   As said, Dr. Walton did not perform these tasks.   She was the

"face" of CGF, together with Dr. Walton, because of her active role

at fundraisers and personal relationships with members of the

foundation.   The PSR also makes clear that she was "very visible

and took an active role in certain fundraising events by selling

tickets, playing host during the events and performing a meet and

greet."   She also acted as the "point person" for the CGF annual

charity golf tournament, working closely with a sports celebrity.

This "very visible" role she played over a number of years was not

that of a person performing ordinary clerical duties.

           She did not merely accept monies raised by the foundation

and act as the keeper of the accounts and books.   There is evidence

she was engaged with persons who did fundraising activities for CGF

and then stole the money they had raised.    She was installed in a

position in which she developed significant relationships with the

families and was the point of contact for fundraising events.    For

example, a former CGF board member and parent of two patients

testified that it was Sicher who gave her two daughters, then 11

and 13 years old, wrist bands to sell in their neighborhood in


                                 -6-
Connecticut as a fundraising effort.   The girls went door-to-door,

raising $300 in cash, which they gave to the defendant in a plastic

bag.   The defendant then took the money.

           Moreover, in at least one instance Sicher was engaged

with a family having a fundraising event about which Dr. Walton

knew nothing.     A former CGF board member testified that she had

held a fundraising birthday party for CGF at her house, working

with Sicher, who never told Dr. Walton about the event.     Sicher

received the money from the event but pocketed it for herself.   The

district court was certainly rational in not inferring that money

raising drives originated and were managed sua sponte without any

involvement by a representative of the charity.

B.         Sicher's Thefts

           In these two roles, in which Sicher admittedly received

minimal supervision, the defendant was able to steal from both Dr.

Walton and CGF.

           1.      Thefts from Dr. Walton's Practice

           Beginning no later than September 2000, the defendant

began to steal from Dr. Walton's medical practice.       She stole

reimbursement checks sent to Dr. Walton from public and private

health insurance programs for medical services by indorsing them

with the forged signature of Dr. Walton and depositing them into

her personal bank account. She took patient payments made by check

to Dr. Walton as well as patient co-payments made in cash.       She



                                 -7-
told one patient he owed an additional $1000 not covered by the

insurance   payment   received    and   then,   when    the   patient   paid,

pocketed    the   money.    Dr.   Walton    did   not    monitor   Sicher's

representations to patients about the sums owed or himself review

the deposits to see that the accounts were correct.

            Over the course of five years of thefts from Dr. Walton's

practice, Sicher stole more than 160 checks from more than 40

different insurers, totaling over $150,000.              To carry out her

thefts, the defendant made, without Dr. Walton's authorization or

knowledge, a signature stamp, which she used to forge Dr. Walton's

signature in indorsing the checks.        Dr. Walton did not review the

checks, and so did not observe this.         The defendant also deleted

various records of the surgeries Dr. Walton had performed for which

payments were still due from the practice's computer files.

            2.      Thefts from CGF

            Sicher was also able to use her position to encourage

fundraising for CGF, to steal from CGF's bank account, and to steal

funds meant to be deposited to the accounts.              She took blank,

unsigned checks for CGF, which were intended for funding research

grants and for which Dr. Walton was the sole authorized signatory.

Sicher made 61 of those checks payable to herself from CGF and

deposited them into her personal bank account, taking a total of

$172,995 from the CGF account.           She also stole at least seven

donations made by check from third parties for a total of $9,850.


                                   -8-
She used the signature stamp she had made of Dr. Walton's signature

to indorse the checks in order to carry out these thefts.                 She also

took cash donations made to CGF, which the defendant told the

government totaled approximately $10,170.                  These actions were

admittedly taken without the authorization of Dr. Walton.                       They

were also taken without his knowledge or permission.               But it is not

the formal job description which is at issue but the actual

responsibilities of her job.

          Sicher was able to conceal these actions because of the

scope of her duties.             For example, she, not Dr. Walton, was

responsible    for     opening     and      reviewing    CGF's    monthly       bank

statements, and presumably reconciling accounts. For at least five

years, she showed Dr. Walton only the first page of the statements

which show the balance for the CGF account.                 She destroyed the

remaining pages that showed the cleared, forged checks. Dr. Walton

deferred to Sicher's representations about the finances of both his

practice and CGF after seeing only the first page of the bank

statements    and    did   not    conduct      a   supervisory   review    of    her

accounting.

          Sicher was given increased responsibilities over the

years because, Dr. Walton said, he trusted her and had confidence

in her.   His office essentially had no checks and balances on the

discretion she had in both of her roles.




                                         -9-
C.         Dr. Walton's Discovery of Sicher's Thefts

           In     November     2005,    Dr.    Walton      discovered    the    first

evidence of Sicher's thefts totally by chance.                      He was in the

office on a Saturday and received and opened the office mail, which

included a bank statement showing that a $25,000 check from CGF to

a    University    of       Georgia    professor     had     been   returned         for

insufficient funds.          Dr. Walton knew that there should have been

enough money in the CGF account for the check to clear; also he had

been surprised not to have received an acknowledgment of the check

from the professor.         When Dr. Walton asked Sicher about the check,

she stated that the check had been sent and that the professor had

called to thank Dr. Walton.             Dr. Walton then confronted Sicher

about the check discrepancy, and she admitted to stealing $4,000

from the CGF account. Investigation established that the defendant

had stolen at least $350,000.

D.         District Court Proceedings

           On January 16, 2007, defendant pled guilty to the 26-

count information.

           The pre-sentence report ("PSR") submitted to the district

court calculated an offense level of 22 under the Guidelines.                        The

PSR recommended a two-level enhancement for abuse of a position of

trust,    U.S.S.G.      §     3B1.3,    a     two-level      enhancement       for     a

misrepresentation that the defendant was acting on behalf of a

charitable   organization,        U.S.S.G.      §   2B1.1,    and   a   three-level


                                        -10-
downward adjustment for acceptance of responsibility, U.S.S.G.

§ 3E1.1.    Sicher's criminal history was calculated at Category I.

            The    PSR's   recommendation       that   the   abuse   of   trust

enhancement should be applied was based on the discretion the

defendant exercised in administering the medical practice and in

managing CGF's activities.            The relevant facts included: that the

defendant had an "extremely high level of trust based upon her ten-

year professional relationship with Dr. Walton"; that she "was

given substantial professional discretion to manage the financial

and administrative functions of the office"; that Dr. Walton "gave

the defendant considerable deference and relied upon her to conduct

his daily affairs"; that Sicher "regularly attended and hosted

fundraisers by the CGF" and was the "face" of CGF along with Dr.

Walton;    and    that   she    had   strong   personal   relationships    with

patients and families "who visited [Dr. Walton's] office in hopes

of finding a cure."            The PSR concluded that "the defendant was

insulated from scrutiny, which contributed significantly to her

ability to facilitate the theft and conceal it on an ongoing basis

thereafter."      Defendant filed an objection to the PSR's conclusion

that the enhancement applied, but did not dispute the underlying

factual assertions.3


     3
          Defendant argued that she was "a secretary who worked
without any clerical support and who was poorly and loosely
supervised" and therefore did not occupy a position of trust. She
further argued that her "ability to accomplish the thefts [was not]
facilitated by the nature of the position she held." The defendant

                                        -11-
              Sicher chose not to present any contrary facts with

respect to her role at CGF and the medical practice to the district

court.    She only submitted evidence regarding her mental health

disorders.     In the mental health evidence, she told         Dr. Reade, who

evaluated her, that she "knew what records Dr. Walton scrutinized

and which he ignored." Sicher knew precisely how to take advantage

of the discretion and minimal supervision she received.

              During   the   pre-sentence     hearing   on   July   12,   2007,

defendant again objected that she did not hold a position of trust.

Importantly, Sicher conceded that in fact she was not supervised.

She attempted to blame Dr. Walton for this, saying he was too busy

and should have hired more staff.

              Before hearing the witnesses at the sentencing hearing,

on   August    2,   2007,    the   district   court   stated   it   had   given

considerable time and thought to what the sentences would be.4


objected that "[i]n the ordinary course in a well-run medical
office, her position is not one in which the employee enjoys great
discretion and 'significantly less supervision' than the usual
clerical worker."
          The Probation Officer responded to the objection, stating
that as Dr. Walton's sole employee, Sicher "was given substantial
professional discretion to manage the financial and administrative
functions of the office and the foundation." Her claims that she
was poorly supervised or that Dr. Walton's office was poorly run
were "unfounded."       The Probation Officer maintained the
recommendation that the enhancement applied based on the evidence
of Sicher's discretionary responsibilities and the trust that Dr.
Walton and the patients had placed in her.
      4
          The district court declined to impose the enhancement for
misrepresentation that she was acting on behalf of a charitable
organization.

                                      -12-
During the sentencing hearing and before defense counsel argued,

defense counsel asked the judge how he had resolved the disputed

Guidelines issue, as it would affect her argument.             The court

responded that "I find that the defendant did violate a position of

trust." Defense counsel did not ask for a greater explanation, nor

did defense counsel present any evidence or any oral argument at

the sentencing hearing that the position Sicher held was not a

position of trust.

          The district court found that both Dr. Walton and CGF

were victims.   The court heard statements from Dr. Walton as well

as four current and former CGF board members, all of whom had

children who were patients of Dr. Walton, and all of whom described

their views that she was trusted by them, and that they took

actions in reliance on that trust, and she had abused the trust.

Sicher did not testify.

          At    sentencing,   the    district   court   also    rejected

defendant's requested a downward departure or variance based on the

evidence she had submitted of her mental health conditions and

announced the 36-month sentence.

          Defendant now appeals her sentence.

                                    II.

          Sicher's first argument is that the district court erred

in applying the enhancement for abuse of a position of trust under

U.S.S.G. § 3B1.3 because she did not hold a position of trust.



                                -13-
Defendant contends that on the factual record presented in the

district court, there was insufficient evidence for the court to

conclude    that    defendant      exercised    the      kind   of   "substantial

professional or managerial discretion" necessary to support the

enhancement.5      We disagree.     The government's burden is to show the

facts    supporting    the      enhancement    by    a   preponderance    of   the

evidence.    United States v. Connell, 960 F.2d 191, 197 (1st Cir.

1992).

            Our caselaw has reviewed the propriety of a § 3B1.3

enhancement under different standards.                   See United States v.

Gonzalez-Alvarez, 277 F.3d 73, 81 (1st Cir. 2002) (giving due

deference to the district court's application of § 3B1.3 to the

facts).    In other cases, we have described the standard of review

as de novo.      United States v. O'Connell, 252 F.3d 524, 528 (1st

Cir. 2001); see also United States v. Parrilla Roman, 485 F.3d 185,

190 (1st Cir. 2007). To the extent that determination depends upon

findings    of     fact,   we    review   the       district    court's   factual

determinations for clear error. O'Connell, 252 F.3d at 528. These

determinations may be made by drawing reasonable inferences from

the evidence.      Marceau, 554 F.3d at 32.




     5
          Defendant argues, citing United States v. Garrison, 133
F.3d 831, 838 (11th Cir. 1998), that there must be a fiduciary or
fiduciary-like relationship between the defendant and victim of the
defendant's fraud.   This is not the law of our circuit, and we
reject the argument.

                                      -14-
          Certainly, questions about interpretation of a guideline

are reviewed de novo.    Marceau, 554 F.3d at 29.     Questions of

application of a guideline tend more to be on a sliding scale.6

For the present case, it makes no difference.   Even if our review

were purely de novo, we would affirm.


     6
          While we have used the language of "de novo" review to
apply to a trial judge's legal conclusion from the facts, we think
this is more like a mixed question of law and fact, with a sliding
scale of review depending on whether the trial judge's conclusion
is more law-oriented or more fact-driven.        Recently the D.C.
Circuit, recognizing that it had used different standards of
review, stated that "insofar as the district court applied the
'abuse of trust' Guideline to the facts of [the defendant's] case,
due deference is the appropriate standard of review."        United
States v. Tann, 532 F.3d 868, 875 n.**** (D.C. Cir. 2008).
          Several circuits state that they review the application
of the Guidelines de novo and the district court's factual findings
for clear error. United States v. Spear, 491 F.3d 1150, 1153 (10th
Cir. 2007); United States v. Andrews, 484 F.3d 476, 478 (7th Cir.
2007); United States v. Brave Thunder, 445 F.3d 1062 (8th Cir.
2006); United States v. Ebersole, 411 F.3d 517, 535-36 (4th Cir.
2005); United States v. Britt, 388 F.3d 1369, 1371 (11th Cir. 2004)
(per curiam), vacated on other grounds, 546 U.S. 930 (2005); see
also United States v. Brogan, 238 F.3d 780, 783 (6th Cir. 2001)
(reviewing de novo decision of a district court to apply § 3B1.3)
          Other circuits have framed the standard of review
somewhat differently. See United States v. Dullum, 560 F.3d 133,
140 (3d Cir. 2009) (district court's determination that defendant
occupied a position of trust reviewed de novo; the court's
determination that defendant abused that position in a manner that
significantly facilitated the offense is a question of fact
reviewed for clear error); United States v. Hirsch, 239 F.3d 221,
227 (2d Cir. 2001) (same); see also United States v. Ollison, 555
F.3d 152, 164 (5th Cir. 2009) ("The application of . . . § 3B1.3 is
a sophisticated factual determination reviewed under the clearly
erroneous standard." (quoting United States v. Fisher, 7 F.3d 69,
70-71 (5th Cir. 1993))); cf. United States v. Thornton, 511 F.3d
1221, 1227 n.4 (9th Cir. 2008) ("Before Booker, we reviewed the
application of the abuse of trust enhancement -- a mixed question
of law and fact -- de novo . . . Although the same standard of
review may well apply after Booker, we need not decide the issue."
(citation omitted)).

                               -15-
            To apply the enhancement, "the district court must first

decide that the defendant occupied a position of trust and then

find that [she] used that position to facilitate or conceal the

offense."   United States v. Gill, 99 F.3d 484, 489 (1st Cir. 1996).

These steps are distinct.     Parrilla Roman, 485 F.3d at 191.

            The district court did not specify the precise basis for

the application of the enhancement, nor did it need to do so.

"[W]e note once more that 'a [sentencing] court's reasoning can

often be inferred by comparing what was argued by the parties or

contained in the pre-sentence report with what the judge did."

United States v. Hoey, 508 F.3d 687, 694 (1st. Cir. 2007) (quoting

United States v. Jiménez-Beltre, 440 F.3d 514, 519 (1st Cir. 2006)

(en banc)).     Indeed, in Rita v. United States, 551 U.S. 338, 359

(2007),   the   Supreme   Court   affirmed   where   there   was   cursory

reasoning by the trial judge, on the basis of inferences as to the

sentencing judge's likely reasoning where "context and the record

make clear that this, or similar, reasoning underlies the judge's

conclusion."

            In reviewing the district court's conclusion, we review

all of the information before the court.         That evidence must be

viewed as a whole and not atomized.          United States v. Hilario-

Hilario, 529 F.3d 65, 78-79 (1st Cir. 2008) (examining district

court evidence including the PSR to evaluate whether the § 3B1.3

sentencing enhancement applied).     Special weight is given to those



                                  -16-
portions of the PSR to which no countervailing proof is offered.

United States v. Prochner, 417 F.3d 54, 66 (1st Cir. 2005) ("The

defendant may object to facts in the PSR, but 'if [his] objections

to the PSR are merely rhetorical and unsupported by countervailing

proof, the district court is entitled to rely on the facts in the

PSR.'" (alteration in original) (quoting United States v. Cyr, 337

F.3d 96, 100 (1st Cir. 2003))).

          A.      Guidelines Requirement

          We begin with whether the government has shown by a

preponderance of the evidence that Sicher occupied a position of

trust.   The Guideline states: "If the defendant abused a position

of public or private trust . . . in a manner that significantly

facilitated the commission or concealment of the offense, increase

by 2 levels."     U.S.S.G. § 3B1.3.      Commentary illuminates the

meaning of the Guidelines.    The commentary states that a "position

of public or private trust" is "characterized by professional or

managerial discretion."      U.S.S.G. § 3B1.3 cmt. n.1.     "Persons

holding such positions ordinarily are subject to significantly less

supervision than employees whose responsibilities are primarily

non-discretionary in nature."      Id.     The Guidelines commentary

further explains that the enhancement would apply to "a bank

executive's fraudulent loan scheme," but does "not apply in the

case of an embezzlement or theft by an ordinary bank teller or




                                 -17-
hotel clerk" because such positions lack the required discretion.7

Id.   The plain language of the Guideline thus covers a spectrum of

positions.      At one end, the enhancement applies to a supervisor to

whom substantial discretion is delegated; at the other end, an

ordinary       bank   teller     with     no    discretion       is    excluded.

               In evaluating the first step of the § 3B1.3 enhancement

analysis, "the relevant inquiry . . . is whether a person in fact

occupied a position of trust, rather than whether the person's

title     or   official   job   description     contained    a    discretionary

element."       United States v. Chanthaseng, 274 F.3d 586, 589 (1st

Cir. 2001) (emphasis in original); see also United States v. Allen,

201 F.3d 163, 166 (2d Cir. 2000) ("An employee need not have a

fancy title or be a 'big shot' in an organization to qualify for an

enhancement for abuse of a position of trust."); United States v.

Barrett, 178 F.3d 643, 646 (2d Cir. 1999) (noting that § 3B1.3

enhancement has been applied to police officers, security guards,

babysitters,      custodians,    and    truck   drivers).        The   fact   that

Sicher's title was only that of secretary and administrative

assistant is beside the point.




      7
          The application note to § 3B1.3 was amended in 1993 to
emphasize managerial or professional discretion and minimal
supervision. See Parrilla Roman, 485 F.3d at 191; United States v.
Reccko, 151 F.3d 29, 33 (1st Cir. 1998). There is no dispute that
we are dealing with the post-1993 version of the Guideline and we
consider relevant cases applying the Guideline with the amended
application note.

                                       -18-
           Under    our    precedent,      the    district        court's implicit

conclusion that Sicher held a position of trust characterized by

managerial discretion cannot be reversed.                The record shows that

Sicher, through her roles in the medical practice and at CGF, in

fact   exercised    a     great    deal   of     discretion       and   had   little

supervision.     These roles must be considered together for purposes

of the enhancement.       What is conclusive for us is her role in CGF.

           Were the enhancement based on Sicher's secretarial role

in Dr. Walton's medical practice alone, this might be considered a

more difficult issue.        Cf. United States v. Tann, 532 F.3d 868,

874-76 (D.C. Cir. 2008) (no enhancement where office manager's

responsibilities     limited       to   payroll   and    entering       checks    into

ledger).   Whether Sicher's secretarial role alone in the medical

practice is enough to support the enhancement is a question we do

not need to reach.           In light of the additional role Sicher

performed at CGF, the evidence firmly supports the district court's

conclusion that she occupied a position of trust.

           The   record     is    clear   that    Sicher     in    fact   exercised

considerable     authority        and   discretion      as   to    CGF;    this    is

necessarily so, as she was unsupervised in a number of tasks as to

receipt and disbursement of funds.                 First, Sicher opened and

reviewed CGF's monthly bank statements and then selectively gave

information to Dr. Walton, who was only shown the bottom line of

the account (i.e. only the first page, which only showed the total


                                        -19-
account balance).          Indeed, she exercised autonomy over incoming

donations, the payments of grants to researchers (as evidenced by

the    non-payment    to    one   researcher),     and    maintenance    of   the

accounting logs. She was essentially unsupervised by Dr. Walton as

to these responsibilities and has never claimed otherwise.

              Second, as the public face of CGF, she was entrusted to

host    CGF    fundraisers     and   to    take   steps   to    facilitate    the

fundraisers such as dealing with celebrities and distributing items

for sale.      She also exercised discretion as to what fundraisers

would be held in CGF's name, not even disclosing them to Dr.

Walton.   Regardless of the defendant's title, she essentially took

over as the de facto manager and director of CGF.

              Where   a    supervisor     fails   to   review    the   financial

transactions carried out by an employee, as here, effectively

giving the employee significant discretion, we have held that the

enhancement applies.         Chanthaseng, 274 F.3d at 590 ("Although it

was against bank regulations for appellant to countersign rapid

deposit tickets at will, the bank manager's laxity effectively made

that a central element of [defendant's] position.").

              Other courts have applied the enhancement to employees

who, despite their title, were in fact entrusted with substantial

discretion. For example, in United States v. Laljie, 184 F.3d 180,

195-96 (2d Cir. 1999), the Second Circuit upheld an abuse of trust

enhancement for a personal secretary who altered checks made



                                        -20-
payable to cash and tricked her employer into signing checks made

payable to her personal accounts.        There, the court explained that

"the proper characterization of the secretarial position for [§

3B1.3] purpose[s] will depend" on the responsibilities the employer

delegates to the employee and the discretion the employer confers.

Id. at 195; see also United States v. Tiojanco, 286 F.3d 1019,

1021-22 (7th Cir. 2002) (enhancement applies to hotel clerk in

accounts receivable department who was responsible for handling

telephone calls from hotel guests who disputed charges made to

their credit card account).

           We recognize that testimony by individuals that they

trusted someone who betrayed their trust does not itself establish

that the position was a position of trust. The testimony, however,

is not irrelevant.       With growing trust by the employer and/or

victim, an employee may be in fact given increasing levels of

responsibility    and   discretion     over   time   which   such   that   the

position becomes one "characterized by professional or managerial

discretion" without any change in title.         That is true here.        Our

caselaw   recognizes    this     as   grounds   to    sustain   a   §   3B1.3

enhancement.    In United States v. O'Connell, this court concluded

that the closeness of the relationship between the defendant and

the   victim   supported   the    district    court's   finding     that   the

defendant occupied a position of trust.              O'Connell applied the

enhancement to a bookkeeper who had forged the business owner's



                                      -21-
name to the checks.        252 F.3d at 528-29.         In upholding the

enhancement,   O'Connell    stated    that   "mere[]    access   to   the

[business's] checkbook and accounting software" was insufficient to

trigger the application of the enhancement.         Id.    Rather, "two

other aspects of O'Connell's employment . . . enabled his thefts:

O'Connell's authority to transfer funds from the line of credit to

the checking account and his close, personal relationship with the

[business owners]."   Id. at 529.       This is a very different point

than saying no more than the defendant lacked supervision.

           The testimony at Sicher's sentencing hearing repeatedly

emphasized the high level of trust Dr. Walton and others had in the

defendant, which resulted in her having an even more important role

in CGF.8

           Although Sicher is correct to argue that "trust" has a

"special meaning" under the Guidelines, United States v. Reccko,

151 F.3d 29, 31 (1st Cir. 1998), it is also evident from the

testimony that the particular level of trust Dr. Walton and the

patients and families had in Sicher "result[ed] in less supervision

of and more autonomy" for her.       O'Connell, 252 F.3d at 529.      And

whatever the reason Sicher was given such a significant role, she

was in fact in a position of trust as defined in the Guideline.

     8
          Sicher was particularly close to the patients and trusted
by them. For example, the secretary of the CGF board described how
the defendant "latched onto us when we were perhaps the most
vulnerable we've ever been." Sicher was described as "accepted as
a member of [the CGF board's] family" and would call his wife six
times a day.

                                 -22-
            The cases upon which Sicher relies to argue that she does

not occupy a position of trust, Reccko and Parrilla Roman, are

easily    distinguished.      In      Reccko,     this   court     rejected     the

application        of   the     enhancement        to    a     police       station

receptionist/switchboard operator who possessed "no discernable

discretion."       Reccko, 151 F.3d at 32.          There, the defendant was

closely    supervised;    her      telephone     lines   were     "continuously"

monitored; and although she announced visitors, "she did not have

discretion either to screen them or to admit them to the non-public

areas of the stationhouse."           Id.     In Parrilla Roman, 485 F.3d at

192, we rejected an enhancement for airport baggage handlers where

there was no evidence of discretion or that defendants "toiled

under    minimal    supervision."        Sicher    did   not     have   a   "menial

position,"     id.,      on     par     with      the    closely        supervised

receptionist/switchboard operator or baggage handler.

            As to the second step, the record clearly shows that

defendant used her position of trust to conceal her offenses.9

There is no dispute that Sicher was able to carry out her offenses

for at least five years by showing Dr. Walton only the first page

of the monthly bank statements and deleting the remaining pages

showing her illegal activity.               The trusted, familial role that

defendant held in Dr. Walton's practice and CGF facilitated the



     9
          On appeal defendant does not contest that her position
enabled her to conceal her offense.

                                       -23-
thefts.   In addition, she used her vast array of responsibilities

with CGF to perform and to conceal her thefts from the foundation.

            Finally, we reject Sicher's second claim of error that

the district court failed to consider and to grant a downward

variance on the basis of evidence of her mental health problems,

including   diagnoses   of   borderline   personality   disorder,   major

depression, and compulsive gambling disorder.

            The record demonstrates that the district court in fact

did consider the defendant's mental health evidence, but simply did

not find it persuasive. The district court stated, "Frankly, while

I understand that, I regard it as an explanation rather than a

justification . . . . Not the kind of mental state to excuse this

criminal behavior." Further, the district court did recommend that

defendant receive mental health treatment in prison.         The record

thus refutes defendant's second claim of error.

                                  III.

            The sentence is affirmed.



                    -Dissenting Opinion Follows-




                                  -24-
          LIPEZ, Circuit Judge, dissenting.            The majority opinion

is a curious blend of intimations and unjustified inferences. With

its invocation of our authority to infer the reasoning of the able

and experienced district court judge, who said that he "had given

considerable time and thought to what the sentences would be," the

majority intimates that we should defer to the decision of the

judge even in the absence of any explanation of his decision that

appellant occupied a position of trust within the meaning of the

guidelines.    With   its   repeated      invocation    of   the   conclusory

assertion of the PSR that Sicher exercised managerial discretion in

carrying out her work for the CGF, an essential characteristic of

a position of trust, the majority intimates that there is evidence

in the record to support that assertion.          Yet when the majority

tries to identify specific instances of the exercise of such

discretion,   there   is    only   an   empty   record.       Therefore,   I

respectfully dissent.

          In Part I of the dissent, I set forth the law that

applies to the position of trust enhancement.           In Part II, I apply

the law to the facts of this case, first addressing appellant's

work as a secretary for Dr. Walton's medical office and then her

work for the Children's Glaucoma Foundation ("CGF").           Although the

majority chooses not to discuss appellant's work as secretary to

the medical office, I must do so because of my view that the

position of trust enhancement was improperly applied.                  In my


                                   -25-
discussion of the application of the law to Sicher's work with the

CGF, I focus on the errors in the majority's analysis.10

                                    I.

             United States Sentencing Guidelines section 3B1.3 calls

for a two-level upward adjustment when "the defendant abused a

position of public or private trust . . . in a manner that

significantly facilitated the commission or concealment of the

offense."     The application notes to this provision explain that a

position of public or private trust refers to one "characterized by

professional      or   managerial    discretion       (i.e.,    substantial

discretionary     judgment   that   is   ordinarily   given    considerable

deference)." U.S.S.G. § 3B1.3 cmt. n.1. The notes further explain

that:

             Persons holding such positions ordinarily are
             subject to significantly less supervision than
             employees whose responsibilities are primarily
             non-discretionary in nature.          For this
             adjustment to apply, the position of public or
             private trust must have contributed in some
             significant way to facilitating the commission
             or concealment of the offense (e.g., by making
             the   detection   of   the   offense    or  the
             defendant's responsibility for the offense
             more difficult).       This adjustment, for
             example,   applies   in    the   case    of  an
             embezzlement of a client's funds by an
             attorney serving as a guardian, a bank
             executive's fraudulent loan scheme, or the
             criminal sexual abuse of a patient by a
             physician under the guise of an examination.


        10
       I concur with the majority's rejection of appellant's claim
that the district court failed to consider the evidence about her
mental health.

                                    -26-
            This adjustment does not apply in the case of
            an embezzlement or theft by an ordinary bank
            teller or hotel clerk because such positions
            are not characterized by the above-described
            factors.

Id.

            We     require   sentencing    courts    to    conduct    a   two-step

inquiry to determine whether the section 3B1.3 enhancement applies

to a particular defendant.          See United States v. Reccko, 151 F.3d

29, 31 (1st Cir. 1998).         First, a court must determine whether a

defendant occupied a "position of trust" within the meaning of the

guideline.        We have called this the "status question."                United

States v. Parilla-Román, 485 F.3d 185, 190-91 (1st Cir. 2007).                  If

the defendant's job does not meet that description, the inquiry

ends and the enhancement does not apply.                  If, however, a court

answers the status question affirmatively, it should proceed to the

second step of the inquiry and ask whether the defendant used her

position of trust to facilitate or conceal her offense.                    Reccko,

151 F.3d at 31; Parilla-Román, 485 F.3d at 190.                 It is error to

conflate these two steps by determining that a defendant "held a

position of trust precisely because her job enabled her to commit

the crime."       Reccko, 151 F.3d at 32; see also Parilla-Román, 485

F.3d   at   191    ("[I]t    does   not   follow    that,    merely   because    a

defendant's position enables him to commit an offense, the position

must have been unsupervised and, thus, a position of trust.").




                                      -27-
       With respect to the status inquiry, our cases -- and the

guideline itself -- reveal that the requirement of managerial or

professional     discretion      is   "paramount."        United   States   v.

Chanthaseng, 274 F.3d 586, 589 (1st Cir. 2001).                Labels do not

matter; it is the defendant's actual degree of discretion, not his

or her job title, that controls the applicability of section 3B1.3.

United States v.    Gill, 99 F.3d 484, 489 (1st Cir. 1996).          Although

positions of trust exist in many different settings, they all

involve:

       . . . situation-specific decisionmaking that is given
       considerable deference precisely because it cannot be
       dictated entirely by established protocol. All of these
       individuals are charged with exercising their judgment in
       the best interest of another person or entity; this is
       the   essence  of   the   "professional   or   managerial
       discretion" to which the guideline refers.

United States v. Tiojanco, 286 F.3d 1019, 1021 (7th Cir. 2002)11;

see also id. at 1020-21 (describing "positions of trust" as falling

into    two   categories:   1)    "people    like   doctors,   lawyers,     and

investment advisors who have (or hold themselves out as having

specialized expertise that leaves the average layman ill-equipped

to     monitor   their   job     performance,"      and   2)   employees    in

organizational settings who are charged with "deciding, on a case-

by-case basis, whether a particular expenditure or transfer of



       11
       The full quotation from this decision refers to "complex,
situation-specific decisionmaking." Id. at 1021 (emphasis added).
I think that the use of the adjective "complex" overstates this
otherwise useful proposition.

                                      -28-
company funds or other valuables is necessary or beneficial to the

organization").

      This focus on the presence of managerial or professional

discretion is necessarily fact-intensive, and the fact patterns

will vary widely from case to case.           Nevertheless, our precedent

provides useful guidance. For example, in Chanthaseng, 274 F.3d at

589-90, we found that a mid-level bank manager occupied a position

of trust when she stole from the bank through a scheme of making

false "rapid deposit" tickets for fictional large cash deposits.

The   defendant's        supervisor   gave   her   the   authority    (against

corporate rules) to countersign her own deposit tickets and failed

to review her tickets, "essentially making her the branch's sole

decision-maker for those transactions."             Id. at 589.       The same

supervisor had also asked the defendant to look into an odd entry

in the bank's records -- one which the defendant in fact created to

conceal her theft -- without providing any oversight for the

defendant's subsequent investigation.           Id. at 590.

      We also found the position of trust enhancement applicable in

United States v. O'Connell, 252 F.3d 524, 528-29 (1st Cir. 2001),

where the defendant was an office manager with access to an

$850,000 line of credit that he could use to transfer funds into

his employer's checking account.         We concluded that "the authority

to    draw   off     the    account    suggests    significant       managerial

discretion."       Id.



                                      -29-
       By contrast, we were not able to identify the presence of

professional or managerial discretion in other cases.                               In Reccko,

151 F.3d at 30-32, we found that the section 3B1.3 enhancement was

inappropriately         applied         to    a    police   station        receptionist        and

switchboard operator who was closely supervised and whose phone

calls were monitored, even though her position made her privy to

secret police information that she used to tip a friend to a

planned drug bust.            Although the defendant's job at the station

"afforded    her      access       to    information,"         it       "reposed    in   her   no

discernable discretion."                Id. at 32.

       We   also      rejected      the       application         of    the    enhancement     in

Parilla-Román, 485 F.3d at 191, where we found that defendants had

not occupied positions of trust as baggage handlers for an airline

even    though       they    had   received          special      security      clearance      in

connection with their employment.                        We noted that the defendants'

positions did not afford them discretion.                                Id.    As our cases

demonstrate, mere access to finances, secure space, or secret

information does not amount to a position of trust unless the

access is accompanied by the exercise of professional or managerial

discretion.

       Distinguishing positions with managerial authority from those

without it can be difficult in the office setting, where employees

often   have     a    wide    range          of   duties    that       must    be   scrutinized

carefully      to     determine          if       they    truly        encompass    managerial



                                                  -30-
discretion.      The difficult line-drawing that may be necessary in

the office setting is illustrated by United States v. Tann, 532

F.3d 868 (D.C. Cir. 2008).        The defendant there was an office

manager who was convicted of fraud for embezzling from three

successive employers.      Id. at 870.     Her duties over the course of

the three jobs included ordering equipment, scheduling travel,

maintaining a check ledger (she was not authorized to sign checks),

ensuring that monthly bank statements matched the ledger, making

out payroll checks, handling cost records, and preparing checks to

be signed by her supervisors.            Id. at 870-71.        Although the

district court had found that Tann was "trusted to handle the

finances    of   the   organization[s],"    it   failed   to   identify    any

specific    tasks   requiring   managerial    discretion.       Id.   at   875

(modification in original) (internal quotation marks and citation

omitted).    In the absence of proof of such tasks, the enhancement

was not applicable.12     Id.

     In United States v. Edwards, 325 F.3d 1184, 1185-86 (10th Cir.

2003), the enhancement did not apply to an administrative assistant

who handled accounts receivable, received customer checks in the


     12
        I note that some of Tann's responsibilities -- such as
hiring employees and managing expenditures, id. at 870-71, -- might
amount to managerial discretion under some circumstances.      Such
tasks are not at issue in this case, and I therefore need not
decide whether they would reflect "managerial discretion" in the
context of appellant's job.    Nonetheless, managing expenditures
might well amount to "managerial discretion" of the kind
contemplated by the guideline, and I am uneasy with Tann to the
extent that it concludes otherwise.

                                   -31-
mail and prepared them for deposit, calculated the balance of

customer    accounts,   posted   payments   to   customer      accounts,   and

prepared cash receipts reports that were incorporated into the

company's ledgers and financial statements.              The Tenth Circuit

stated that "the adjustment under § 3B1.3 is not intended to be

routinely    applied    to   every    employee   fraud    or    embezzlement

case. . . . [T]he fact is that in every successful fraud the

defendant will have created confidence and trust in the victim, but

the sentencing enhancement is not intended to apply to every case

of fraud."     Id. at 1187 (internal quotation marks and citation

omitted).    Because Edwards's job "was purely ministerial and did

not entail substantial discretionary judgment," the section 3B1.3

enhancement was inappropriate.        Id.

                                     II.

     In imposing the abuse of trust enhancement in this case, the

district court made no factual findings on the record concerning

the nature of appellant's position and whether it required the

exercise of professional or managerial discretion.             The court had

before it, however, the charging document to which appellant pled

guilty, victim impact letters written by Dr. Walton on behalf of

himself and the CGF, the victim impact testimony of Dr. Walton and

parents of some of his patients, appellant's psychiatric and

compulsive gambling evaluations and, most importantly, the PSR.

Appellant did not contest the objective facts set forth in any of


                                     -32-
these sources.        The district court was entitled to accept those

uncontested facts as true. United States v. Prochner, 417 F.3d 54,

66 (1st Cir. 2005).

       In   contrast    to   the   objective     facts   (which    include,     for

example, the specific tasks Sicher performed, the descriptions of

events occurring during the course of her fraud, and the amount of

money she stole), appellant did contest a critical conclusion drawn

from those facts that would, if true, support the imposition of the

position of trust enhancement.             Namely, she contested the PSR's

assertion that she "was given substantial professional discretion

to    manage    the   financial    and    administrative    functions      of   the

office," arguing in her sentencing memorandum that her job "was not

one    that     was   'characterized       by   professional      or   managerial

discretion.'"         Defendant's Sentencing Memorandum at 2 (quoting

U.S.S.G.       § 3B1.3).     Unlike the majority, I do not merely accept

the    PSR's     conclusion     that     appellant   was   given       substantial

discretion, or the district court's unexplained finding that "the

defendant did violate a position of trust."                The district court

made no subsidiary findings of fact about whether appellant's

position afforded her managerial discretion.               "In a case such as

this one, in which the district court announced its decision to

adjust upward without any subsidiary findings of fact, we 'review

the evidence and the result, [but] not the reasoning by which the

result was reached by the district court.'"              Chanthaseng, 274 F.3d


                                         -33-
at 589 (quoting United States v. Tracy, 36 F.3d 199, 203 (1st Cir.

1994)).

     The majority invokes the ability of the district court to make

factual determinations by drawing reasonable inferences from the

evidence, and our ability to infer a sentencing court's reasoning

under     certain       circumstances.        Those       propositions,     while

unquestionably correct, are irrelevant to this case.               Whatever the

intricacies of the review process here,13 my conclusion is that any

inferences fairly drawn from the record simply do not support the

conclusion that appellant occupied a position of trust.

A. Administrative Assistant to Dr. Walton's Medical Office

     The PSR states that Dr. Walton relied on appellant to "conduct

his daily affairs," giving her "substantial professional discretion

to manage the financial and administrative functions of the office."

These generalities, repeated by the government in its brief, draw

no support from the specific responsibilities attributed to Sicher.

Her specific duties, as set forth in the PSR, included ministerial

tasks     such    as    opening   mail,    welcoming      patients,   scheduling

appointments, bookkeeping, and collecting and depositing payments.

These     kinds    of    ministerial      tasks   do     not   normally   require

"substantial      discretionary     judgment      that    is   ordinarily   given


     13
       I do agree with the majority's suggestion in footnote 6 of
its opinion that our review of the imposition of the position of
trust enhancement ordinarily involves a "mixed question of law and
fact, with a sliding scale of review depending on whether the trial
judge's conclusion is more law-oriented or more fact-driven."

                                       -34-
considerable deference,"      U.S.S.G. § 3B1.3 cmt. n.1, and the record

gives us no reason to conclude that they did in this situation.

Notably, the record does not reveal that appellant had authority to

make spending decisions for the medical office, prepare a budget,

approve     or    deny   spending   requests,     or   conduct   any   other

discretionary task with respect to the "financial and administrative

functions    of    the   office."    While   is    true   that   appellant's

responsibilities gave her the opportunity to commit her crimes, they

"reposed in her no discernable discretion." Reccko, 151 F.3d at 32;

see also United States v. Spear, 491 F.3d 1150, 1154 (10th Cir.

2007) ("'The fact that [the defendant] was trusted by her employer

with significant responsibility . . . is not determinative.'"

(alterations in original) (quoting Edwards, 325 F.3d at 1187)).

B. Administrative Assistant to the Children's Glaucoma Foundation

     The following two paragraphs are the core of the majority's

erroneous reasoning about the significance of appellant's work for

the CGF:

     The record is clear that Sicher in fact exercised
     considerable authority and discretion as to CGF; this is
     necessarily so, as she was unsupervised in a number of
     tasks as to receipt and disbursement of funds. First,
     Sicher opened and reviewed CGF's monthly bank statements
     and then selectively gave information to Dr. Walton, who
     was only shown the bottom line of the account (i.e. only
     the first page, which only showed the total account
     balance). Indeed, she exercised autonomy over incoming
     donations, the payments of grants to researchers (as
     evidenced by the non-payment to one researcher), and
     maintenance of the accounting logs. She was essentially
     unsupervised by Dr. Walton as to these responsibilities
     and has never claimed otherwise.

                                    -35-
          Second, as the public face of CGF, she was entrusted
     to host CGF fundraisers and to take steps to facilitate
     the fundraisers such as dealing with celebrities and
     distributing items for sale.        She also exercised
     discretion as to what fundraisers would be held in CGF's
     name, not even disclosing them to Dr. Walton. Regardless
     of the defendant's title, she essentially took over as
     the de facto manager and director of CGF.

These paragraphs contain both factual and legal errors. I will deal

with the factual errors first, setting forth the assertions at issue

in bold print.

     1. Factual Errors

          a. "Sicher opened and reviewed CGF's monthly bank
statements and then selectively gave information to Dr. Walton, who
was only shown the bottom line of the account (i.e. only the first
page, which only showed the total account balance)."

     This statement only describes the technique of Sicher's crime;

her concealment of illicit transactions does not show that she was

authorized to exercise managerial discretion on behalf of the CGF.

While Sicher, as a bookkeeper, may have been the only one to review

the itemized record of the bank account's activity, that fact does

not indicate that she was authorized to exercise discretion over the

transactions reported there.

          b.    Sicher   "exercised    autonomy    over    incoming
donations . . . ."

     Sicher "exercised autonomy" over incoming donations only to the

extent that she was the sole person responsible for depositing them

in the CGF's bank account.14   She exercised no authority over the


     14
       The majority cites Chanthaseng, 274 F.3d at 590, for the
proposition that "when a supervisor fails to review the financial

                               -36-
funds in that account, however, because she was not permitted to

choose where they should be deposited or how they should be spent.

She had no authority to write checks from the CGF's bank account.15

          c. Sicher "exercised autonomy over . . . the payments of
grants to researchers."

     If this statement were true -- for example, if Sicher had the

authority to decide which researchers were to be paid, how much, or

even when -- that fact would indeed support the majority's position

that she exercised discretion in her role.    However, there is no

evidence to support that proposition.    Certainly, the episode on

which the majority relies to make the assertion (when Dr. Walton

discovered appellant's thefts because a check to a researcher was




transactions carried out by an employee, as here, effectively
giving the employee significant discretion, we have held that the
enhancement applies." The facts of that case, however, are quite
different. The defendant in Chanthaseng became the "sole decision-
maker" for certain financial transactions.       Id. at 589.     By
contrast, appellant was not authorized to make any decisions about
financial transactions for the CGF and the medical office. She was
not authorized to write checks, manage, or move money; she was only
authorized to deposit it in a specified account. As with the case
of an embezzling bank teller, the fact that she did otherwise does
not make hers a position of trust.
     15
          The PSR explains:

     The CGF had a supply of blank, unsigned checks at Dr.
     Walton's office, which were drawn off of the CGF account
     and intended primarily for use in funding research
     grants. During all relevant periods, Dr. Walton was the
     named trustee and sole authorized signatory on the CGF
     bank account. He neither delegated signature authority
     to Sicher, nor authorized, directed, or otherwise
     suggested that Sicher obtain a signature stamp with his
     name.

                               -37-
returned for insufficient funds) does not support the contention.

Dr. Walton discovered the theft when, to his surprise, he saw that

the check to the researcher had bounced; he knew that there should

have been enough money in the account to cover it.    That episode

only supports the conclusion that Sicher, without the authorization

or knowledge of Dr. Walton, drained the account of money. It cannot

support the inference that Sicher had "complete autonomy" over

research grant payments. While she might possibly have prepared the

check to the researcher (a fact the record does not provide), she

was, without question, unauthorized to sign it on her own.

          d. Sicher "exercised autonomy over . . . maintenance of
the accounting logs."

     This statement is probably true. Sicher was the bookkeeper for

the CGF as well as the medical office.        As we indicated in

O'Connell, 252 F.3d at 528-29, however, that ministerial task does

not indicate the use of discretionary judgment.    See id. (noting

that "[t]here is some support for O'Connell's argument that his

position as a bookkeeper . . . did not place him within the

Guideline definition of a position of a trust," but finding support

for the imposition of the enhancement in other aspects of the

defendant's job).




                               -38-
           e. "[A]s the public face of CGF, [Sicher] was entrusted
to host CGF fundraisers and to take steps to facilitate the
fundraisers such as dealing with celebrities and distributing items
for sale."

      Sicher was a "host" of CGF events only in the sense that she

was a greeter and a "face" of the charity.             The record shows that

she was called on to use her social skills on behalf of the

organization, not her managerial discretion.               For example, the

majority focuses on an episode, described at sentencing by the

mother of a patient, when Sicher gave wristbands to two girls who

sold them to raise money for the charity.              The disbursement of a

fundraising item, and the subsequent theft of the money raised, does

not   reflect   the   use,   especially    not   the    authorized   use,    of

managerial discretion.       Nothing in the record indicates that Sicher

planned, designed, or developed the bracelet fundraiser.

          f.    Sicher "also exercised discretion as to what
fundraisers would be held in CGF's name, not even disclosing them
to Dr. Walton."

      Nowhere does the record support the contention that Sicher

exercised discretion about what fundraisers would be held.                  The

majority apparently draws this conclusion from the testimony about

a birthday party held by a former member of the CGF's Board of

Directors, who said at sentencing:

      [M]y husband and I had a birthday party in our home and
      every guest there donated money to the foundation,
      directly to the foundation. But, Dr. Walton never heard
      of this. Because, the defendant decided rather than to
      give this money to research and to study, she would put
      it in her own pocket. She would steal from my children,
      from all of these children.

                                    -39-
This testimony describes Sicher's use of the birthday party to steal

money, not her exercise of discretion in planning and implementing

the party.         Nor does          the    testimony support the more general

conclusion that anything about Sicher's position -- explicitly or

implicitly -- gave her authority to use discretion about what

fundraisers to hold.

          g.   "Regardless of defendant's title, she essentially
acted as the director of the CGF."

            As     I    have    indicated,      the    facts    belie   this   wishful

characterization.            Strikingly, Sicher was paid only an additional

$150 per month for her work on behalf of the CGF.                          That modest

increment     is       not    surprising.           Contrary    to   the    majority's

suggestions, the record does not indicate that appellant made any

decisions    on    behalf       of    the    CGF,   such   as   determining    how   to

fundraise, setting financial goals, or choosing how to spend its

money.   She did not have authority to write checks, prepare the

budget, or supervise employees.                 Appellant's position at the CGF

afforded her access to the funds she ultimately stole, but it did

not require the exercise of managerial discretion.

     2. Legal Errors

         The majority's opinion attempts to draw too certain a

connection between the lack of supervision and the exercise of

discretion.        The government makes the same error in its brief,

suggesting that the section 3B1.3                    enhancement was appropriate

because of Sicher's lack of supervision and her close relationship

                                             -40-
with Dr. Walton and the families who visited his office. It is true

that lack of supervision often characterizes positions that require

the exercise of managerial discretion.                   The guideline commentary

makes that very point: "[p]ersons holding such positions ordinarily

are subject to significantly less supervision than employees whose

responsibilities           are   primarily    non-discretionary         in    nature."

U.S.S.G.      §    3B1.3    cmt.   n.1.      It   does     not    follow     from   that

observation, however, that lack of supervision of an employee means

that the employee is necessarily authorized or expected to exercise

professional or managerial discretion.                  In some circumstances, the

ministerial nature of the task may not justify much supervision.

Although the guideline requires the exercise of managerial or

professional discretion to apply the enhancement, it only suggests

that   lack       of   supervision   is    one    way    to   detect   whether      that

discretion exists.           The majority asserts the opposite, concluding

that Sicher "in fact exercised considerable authority and discretion

as to CGF; this is necessarily so, as she was unsupervised in a

number of tasks as to receipt and disbursement of funds."

       Likewise, the majority makes the error of equating simple trust

with a section 3B1.3 "position of trust," a link long rejected by

this circuit.          See Reccko, 151 F.3d at 31.               The majority states

that, "[w]ith growing trust by an employer, and/or victim, an

employee may be in fact given increasing levels of responsibility

and discretion over time [] such that the position becomes one



                                          -41-
'characterized by professional or managerial discretion' without any

change    in   title.'"      That     observation     may   be    apt    in   some

circumstances, but the record does not support it here.                 Sicher had

access to the finances of the CGF and the medical office because she

was trusted, but she was not permitted to exercise her discretion

over those finances.16

     The majority also embraces the government's argument that our

decision in O'Connell, 252 F.3d 524, supports its contention that

Sicher's close relationships with Dr. Walton and the families of his

patients transformed her role into a "position of trust" within the

meaning of section 3B1.3.           The majority describes O'Connell as

holding   that   "the     closeness    of    the   relationship    between    the

defendant and the victim supported the district court's finding that

the defendant occupied a position of trust."             While that is true,

our decision in that case critically depended on the trusted

relationship in combination with the defendant's "unfettered access

to an $850,000 line of credit" which he had "authority to transfer

     16
        The Second Circuit has more recently relied on the
proposition that "applicability of a § 3B1.3 enhancement turns on
'the extent to which the position provides the freedom to commit a
difficult-to-detect wrong.'" United States v. Allen, 201 F.3d 163,
166 (2d Cir. 2000) (quoting United States v. Viola, 35 F.3d 37, 45
(2d Cir. 1994); see also United States v. Laljie, 184 F.3d 180,
195-96 (2d Cir. 1999).        We have explicitly rejected that
proposition. See Parilla-Román, 485 F.3d at 191; Reccko, 151 F.3d
at 33 ("It is true that in dealing with the position-of-trust
enhancement courts occasionally have emphasized the employee's
freedom to commit wrongs that defy facile detection. But these
decisions deal with earlier versions of § 3B1.3 and, thus, antedate
the Sentencing Commission's emphasis on managerial or professional
discretion . . . .").

                                      -42-
. . . to the checking account."         Id. at 529.   We stated that "the

authority to draw off the account suggests significant managerial

discretion," a conclusion that was bolstered by the district court's

finding that the defendant had a close personal relationship that

led to "more autonomy for O'Connell."          Id.    We can accept that

Sicher's close, trusted relationships with Dr. Walton and the

families   of   his   patients   were   comparable    to   the   family-like

relationship of O'Connell with his employer, and that this closeness

gave Sicher access to money that she could embezzle.                However,

unlike O'Connell, appellant had no ability to exercise decision-

making authority in her position as administrative assistant to the

CGF.17

                                   III.

     There is no question that appellant committed a terrible

"betrayal of trust" within the colloquial understanding of that

phrase.    Dr. Walton trusted her to deposit income into the medical

office's account, and his young patients and their families trusted

that the CGF would benefit from the donations they gave to her for

safekeeping and deposit.     At sentencing, Dr. Walton and parents of


     17
        Importantly, we remarked in O'Connell that, taken alone,
O'Connell's lack of legal signatory authority on the company's
checking account, and the fact that he clearly exceeded his
authority by writing checks to himself, would have suggested "that
it was not professional discretion that facilitated the commission
of O'Connell's crimes, but merely his access to the [company]
checkbook." 252 F.3d at 528. In this sense, Sicher's situation is
comparable to O'Connell's: she had access to the office and CGF
checking accounts, but no signatory authority on either account.

                                   -43-
his   patients    described    the   detrimental     effect   of     appellant's

betrayal on their ability to trust others.                 The district court

described her breach of trust as "egregious" and "an amazing

violation of trust," and I agree.

         "The     sentencing   guidelines,     however,     create    their   own

vocabulary -- and the guidelines sometimes define terms in ways that

might strike lay persons as peculiar.          So it is here: in the idiom

of the sentencing guidelines, the term 'position of public or

private trust' has a special meaning."         Reccko, 151 F.3d at 31.         As

the application notes explain, the position-of-trust enhancement

applies only to those positions "characterized by professional or

managerial discretion (i.e., substantial discretionary judgment that

is ordinarily given considerable deference)." U.S.S.G. § 3B1.3 cmt.

n.1. Even accepting all of the objective facts set forth in the PSR

and elsewhere in the record as true (as the district court was

entitled to do in the absence of any challenge to them), the facts

are insufficient to support the imposition of the position of trust

enhancement because they do not indicate that appellant had a

position that afforded her discretion.             If one looks beyond the

PSR's conclusory assertion that appellant had discretion "to run the

financial   and    administrative    affairs    of   the    office,"    and   the

district court's unexplained application of the position of trust

enhancement, the record does not reveal any tasks requiring the

exercise of judgment and the decisionmaking authority that are the



                                     -44-
essence   of   managerial   discretion   within   the   meaning   of   the

guideline. See Tiojanco, 286 F.3d at 1021. Instead, one finds only

ministerial tasks and the exercise of social skills.

     Unfortunately, in an effort to affirm the district court, the

majority has significantly      diluted the guidelines' concept of

professional and managerial discretion.     Moreover, contrary to our

precedent, the majority comes perilously close to equating lack of

supervision with the exercise of discretion.      Thus, the majority's

conclusion that the application of the position of trust enhancement

was proper in this case represents a sharp departure from our

precedent and the once coherent body of law that applied to this

issue.    I respectfully dissent.




                                 -45-