Winters was convicted of violations of 18 U.S.C. § 242 (depriving an individual of his civil rights under color of law), 18 U.S.C. § 924(c) (use of a firearm during and in relation to a crime), and 18 U.S.C. § 1503 (obstruction of justice). The district court departed downward from the United States Sentencing Guidelines at sentencing. The government appealed. This court held that the district court abused its discretion in sentencing Winters, vacated the sentence, and remanded for re-sentencing. The district court again departed downward from the guidelines, this time listing different reasons for departure. The government again appeals the sentence. For the reasons stated herein, we vacate the sentence and remand for resen-tencing.
Factual Background and Procedural History
This appeal revisits the sentence of Terry Lynn Winters (Winters), which this court first reviewed in United States v. Winters, 105 F.3d 200 (5th Cir.1997). Winters was a correctional officer at the Mississippi State Penitentiary at Parch-man, Mississippi (Parehman). At the time of his arrest, Winters had worked for Parehman for fifteen years.
In November 1991, inmate Larry Floyd escaped from Parehman in a stolen vehicle. Floyd wrecked the vehicle and sustained injuries which left blood around the vehicle. The following day Floyd was captured at an abandoned house. Several officers beat Floyd after he was handcuffed despite the absence of resistance on his part. The officers then placed Floyd in a truck for return to the prison. During the trip, Winters squatted over Floyd and hit him several times forcefully on the head with his service revolver knocking him unconscious. A small artery in Floyd’s head was severed by the head blows resulting in profuse bleeding. The Parehman staff physician testified that the wound on Floyd’s head was consistent with “the type of wound that might result from a blow by a gun barrel.”
A federal grand jury investigated the incident. The grand jury subpoenaed *481Robert McKnight to testify. McKnight was also a Parchman officer who had also participated in the capture and beating of Floyd. Winters was McKnight’s superior officer. The night before McKnight was to testify, Winters and another officer visited McKnight and pressured him to testify falsely.
The grand jury indicted Winters and four others for various federal offenses. Winters was convicted of deprivation of a person’s civil rights under color of law (18 U.S.C. § 242), use of a firearm during and in relation to a crime (18 U.S.C. § 924(c)), and obstruction of justice (18 U.S.C. § 1503).
Under the United States Sentencing Guidelines, (USSG or guidelines), a violation of 18 U.S.C. § 924(c) (use of a firearm during a crime) carries a mandatory minimum sentence of sixty months’ imprisonment. Winters faced an additional 108— 135 months’ imprisonment for the convictions under 18 U.S.C. § 242 (deprivation of civil rights) and 18 U.S.C. § 1503 (obstruction of justice). The guidelines also required a fine ranging from $20,000— $200,000, two to three years of supervised release, and a $150 special assessment.
The court departed downward from the guidelines. The court sentenced Winters to the mandatory sixty months for the firearms charge. The sixty months would be served consecutively with an additional twelve months for each of the other two convictions (to be served concurrently). Thereafter Winters was sentenced to three years supervised release, a $2000 fine and a $150 special assessment.
The government appealed Winters’ sentence. As a preliminary matter, this court had to determine on what grounds the district court based the departure. The government argued that the district court based its decision on three grounds, and asked this court to declare each reason an improper basis for departure. Those grounds were: (1) that Winters’ act was a “single act of aberrant behavior;” (2) Winters’ distinguished record of service as a correctional officer; and (3) an institutional norm that a prisoner who escaped would be beaten upon recapture. A panel of this court disagreed with the government’s interpretation of the sentencing colloquy. It found that the district court justified its departure on the sole ground that Winters’ act was a single act of aberrant behavior, which was inconsistent with his prior service and high virtues. See Winters, 105 F.3d at 206.
The panel found that the district court’s interpretation of Winters’ actions was unsupported by the record. See id. at 207 (“A single act of aberrant behavior can be an appropriate basis for a downward departure ... -. However, such a single act is not implicated by Winter’s conduct.”). Therefore this court vacated Winters’ sentence and remanded for re-sentencing.
In February 1998, the district court again notified the government that it would depart from the guidelines. This time, the district court listed its grounds as (1) a “Correctional Officer’s High Susceptibility to Abuse in Prison” and (2) the “Mandatory and Consecutive 5-year Term of Imprisonment on Count 5 [the gun charge] results in an Excessive Term of Imprisonment.” The government timely objected to the departure. Based on the aforementioned grounds for departure, the district court sentenced Winters to the same sentence as before. The government again appeals Winters’ sentence.
Discussion
The government raises three issues in this appeal. First, the government contends that the district court abused its discretion by departing downward on the basis that Winters faces a mandatory 60 month term for the gun charge. Next, the government explains that the district court abused its discretion when it offered Winters’s status as a correctional officer as basis for a downward departure. Finally, the government urges this court to reassign this case to a different judge.
*482A. Abuse of Discretion
This court reviews a district court’s departure from the sentencing guidelines for abuse of discretion. See Koon v. United States, 116 S.Ct. at 2035. “[Wjhether a factor is a permissible basis for departure under any circumstances is a question of law and the court of appeals need not defer to the district court’s resolution of that point.” See Koon, 116 S.Ct. at 2047. However, this review is still included under the abuse of discretion standard. See id. (“A district court by definition abuses its discretion when it makes an error of law.”).
A district court’s determination whether to depart from the guidelines is entitled to substantial deference, “for it embodies the traditional exercise of discretion by a sentencing court.” See Winters, 105 F.3d at 204. This is due primarily to the particular competence of trial courts in determining whether a particular case is ordinary or unusual, as compared to the vast majority of other cases.1 See id., discussing Koon, 116 S.Ct. at 2047.
However, a district court cannot depart from the guidelines unless it first finds, on the record, that facts or circumstances of a case remove that case from the “heartland” of typical cases encompassed within the guideline. See Winters, 105 F.3d at 205; United States v. Harrington, 82 F.3d 83 (5th Cir.1996) (court must articulate acceptable reasons for departure on the record and departure must be reasonable).
The Guidelines Manual explains that it intends each guideline to create a heartland of typical cases. See Guidelines, ch.l, pt. A. See also Koon, 116 S.Ct. at 2044. A court should not depart from the guidelines unless it finds that conduct in a particular case “significantly differs from the norm,” and takes the case outside this heartland. Id. Put another way, a sentencing court may depart “if it finds ‘unusual circumstances’ that render the guideline level attached to a specific factor insufficient.” See United States v. Caldwell, 985 F.2d 763 (5th Cir.1993), citing USSG § 5K2.0,18 U.S.C. § 3533(b).
Additionally, the guidelines either forbid, discourage, or encourage several factors as bases for departure. See id; See USSG § 5H1. Forbidden factors, such as race, sex, and national origin, may never be considered by a sentencing court. See § USSG 5H1.10. Discouraged factors, including employment records and family ties, are considered “not ordinarily relevant” and may only be considered “in exceptional cases.” See USSG § 5H1.5, ch.5, pt. H; Koon, 116 S.Ct. at 2045.
Alternatively, a sentencing court may depart from the guidelines if “it finds an aggravating or mitigating circumstance that was not adequately taken into consideration by the Sentencing Commission in formulating the sentencing guidelines.” See id. To determine whether a circumstance was adequately considered by the Commission, courts may “consider only the sentencing guidelines, policy statements, and official commentary of the Sentencing Commission.” United States v. Koon, 518 U.S. 81, 116 S.Ct. 2035, 2044, 135 L.Ed.2d 392 (1996), quoting 18 U.S.C. § 3553(b).
*4831. Mandatory 60 Month Gun Charge As Basis for Departure
The district court determined that in light of the mandatory sixty month sentence required for the gun charge, following the guidelines on the other charges would impose too harsh a sentence. Therefore, the district court departed downward from the guidelines on the sentences for the civil rights and obstruction of justice charges.
No permissible basis for departure was provided by the gun charge. In United States v. Caldwell, this court considered whether the fact that a defendant faced a mandatory minimum sentence for the use of a firearm during a crime, pursuant to 18 U.S.C. § 924(c), could justify a downward departure from the guidelines for the underlying crime. See United States v. Caldwell, 985 F.2d 763, 764-65 (5th Cir.1993). It cannot.
The defendant in Caldwell had been caught exchanging drugs in a hotel room, where law enforcement officers found a gun. See Caldwell, 985 F.2d at 764. Caldwell pleaded guilty to a drug offense and to the use of a firearm in the commission of that crime (pursuant to 18 U.S.C. § 924(c)). See id. The district court noted that the gun charge carried a mandatory minimum sentence of sixty months’ imprisonment. See id. The district court determined that, because the gun played only a minimal role in the crime, following the guidelines on the drug offense would result in an unduly harsh sentence. See id. Since the court was not able to depart downward on the gun charge, the court departed downward from the guidelines on the underlying drug offense. See id.
This court reversed. See id. at 765. The guidelines permit departure only where a mitigating or aggravating factor is not adequately taken into consideration by the guidelines themselves. See id. In the case of a § 924(c) charge, however, “the guidelines do consider. the interplay of § 924(c) and themselves.” See id. As we previously explained, the guidelines specifically control the sentencing of defendants convicted under § 924(c) and the underlying offense. See id. See also USSG § 2K2.4 (limiting additional offense-specific enhancement for use or possession of a weapon where a defendant has also been sentenced under § 924(c)). Furthermore, the guidelines anticipate that the underlying offense level will already be reduced when there is a separate gun charge because the underlying offense-level will not include any applicable weapons enhancement.2 Accordingly, the defendant in Caldwell had not been sentenced to an additional weapon enhancement for his underlying drug offense.
The Sentencing Commission thoroughly considered the interplay of the mandatory minimum sentence for use of a firearm with the sentence guidelines for the underlying crimes. The guidelines prohibit a court from departing from the guidelines based on a factor that the Sentencing Commission considered in formulating the guidelines. See Caldwell, 985 F.2d at 765. Therefore, this court held as a matter of law that a mandatory minimum sentence under 924(c) cannot justify a downward departure for the underlying offense.’ See id.
Under Caldwell, therefore, the mere fact that Winters faced a sixty-month minimum sentence on the gun charge cannot by itself justify a departure from the guidelines. Thus, the district court’s departure was allowable only if unusual circumstances remove this case from the heart*484land of cases contemplated by the guidelines.
The district court determined that this is an unusual case for which the guidelines are inadequate. First, the court noted that Winters lawfully possessed his weapon. See id. The court recognized that Winters’ lawful possession of the gun was not sufficient grounds for departure, but stated that it added to the totality of the circumstances calling for departure. Id. at 28. Second, the court recognized the fact that Winters was a law enforcement officer, and noted his service record. “Let me inject this. If ever there has been an unusual case under the guidelines it is that this 15-year veteran of law enforcement with the Department of Corrections who, the evidence shows, had an unblemished record and who exhibited this type of behavior.” See id. at 29.
A district court’s determination of what is a usual or unusual case is entitled to substantial deference. See Koon, 518 U.S. 81, 116 S.Ct. 2035, 135 L.Ed.2d 392. However, the district court offered no facts which differentiate this case from any other ease in which a law enforcement officer uses excessive force or obstructs justice.
Instead, the district court found this case extraordinary primarily because of Winters’ personal characteristics. Personal traits such as those relied upon by the district court are not proper bases for departures from the guidelines. See Winters, 105 F.3d at 206. See also United States v. O’Brien, 18 F.3d 301, 303 (5th Cir.1994) (holding that departure based on assessment of defendant’s good character is inconsistent with guidelines); Harrington, 82 F.3d at 88 (recognizing that a defendant’s personal characteristics are not usually acceptable grounds for departure).
For example, Winters’ status as a correctional officer and his fifteen year service history do not provide proper grounds for departure. Employment status and records of civic or public service are discouraged factors under the guidelines, and can therefore be grounds for departure only in exceptional cases. See USSG § 5H1.5, 11. The fact that Winters worked for the prison system for fifteen years surely does not by itself take Winters out of the “heartland” of officers normally convicted of violating an inmate’s civil rights. See also United States v. Rybicki, 96 F.3d 754, 758 (4th Cir.1996) (Vietnam Veteran with 20 years military service and responsibilities to mentally ill wife and sick son did not present “exceptional” case).
Furthermore, Winters’ status as a correctional officer is closer to an aggravating factor rather than a mitigating one. See Winters, 105 F.3d at 207. Winters’ status as a corrections officer necessarily meant that the criminal conduct—which took place in his capacity as a corrections officer—constituted an abuse of a public position. The guidelines specifically state that crimes involving the abuse of public trust may be considered aggravating—not mitigating—-factors. See id., citing USSG § 3B1.3. See also Winters, 105 F.3d at 207 (“[T]he Commission considered criminal acts committed by government agents to require a firmer response in order to prevent them.”).
The guidelines also discourage departures based on family ties and responsibilities. See USSG § 5H1.6. Accordingly, courts should only depart from the guidelines on these bases in rare or exceptional cases. See id. There is no evidence that Winters’ family will suffer any more than any family suffers when one member is sentenced to prison. See Harrington, 82 F.3d at 89; United States v. Kapitzke, 130 F.3d 820 (8th Cir.1997) (“[T]he disintegration of existing family life or relationships ... is to be expected when a family member engages in criminal activity that results in a period of incarceration.”), citing United States v. Canoy, 38 F.3d 893, 907 (7th Cir.1994). Thus, Winters’ family ties do not present a valid basis for departure.
*485The district court held that all these factors should be taken into consideration together, to take them outside the heartland of the guidelines. Indeed, the district court seems to have felt that the severe punishment required by the guidelines in this case didn’t fit the crime. See R.E. Tab 6 p.257 (“The facts in this case do not warrant a sentence within the applicable guideline’s range for counts 4 and 9 PLUS an additional 5-year mandatory and consecutive term of imprisonment on count 5.”). The Sentencing Commission recognized that such a case might occur, where several otherwise-insufficient factors combined to justify a departure. See Commentary accompanying § 5K2.0. However, the Commission stated such cases would be “extremely rare.”
This is not such an extremely rare case. Moreover, the district court has not articulated “relevant facts and valid reasons” demonstrating why this case is extraordinary or even unusual in comparison to other cases under the guideline. See Winters, 105 F.3d at 208. Once again “the district court’s reasoning fails to cite the compelling facts necessary to satisfy the very high standard for this type of departure from the Guidelines.” See id. Therefore, the district abused its discretion in departing from the guidelines.
2. Status as Correctional Officer as Basis for Departure
The district court’s second basis for departure was the fact that Winter’s status as a corrections officer makes him highly susceptible to abuse in prison. Winters had been an officer in Mississippi prisons for over fifteen years when the incident occurred. During that time, the district court reasoned, he had met many prisoners. Some of these prisoners would now likely be in federal prison. Those prisoners would know that Winters had been a corrections officer. The district court determined that this circumstance justified a departure based on Winters’s apparent high susceptibility to abuse by other prisoners.
In Koon, the United States Supreme Court held that the district court properly considered the defendants’ particular susceptibility to abuse in prison as a basis for a downward departure. See id. However, Koon was an extreme case and no facts remotely similar to it are present here. Koon involved the sentencing of the Los Angeles Police Department officers convicted of beating Rodney King. The district court found that the “extraordinary notoriety and national media coverage of this case, coupled with the defendants’ status as police officers, make Koon and Powell unusually susceptible to abuse in prison.” See Koon, 116 S.Ct. at 2053.
Any attempt to compare this case to the Rodney King incident is unavailing. A few stories in a local or state-wide newspaper cannot compare to the national outrage emanating from the beating of Rodney King, not to mention the subsequent riots. The notorious circumstances involved in Koon and the identity of the officers involved received such sustained national media coverage as to permeate prison facilities nationally. There is no record evidence to show that the instant event was reported beyond the local area of its occurrence. Winters argues that this case is unique because he was a corrections officer accused of beating an inmate. However, his situation is not outside the heartland of cases in which a law enforcement officer is accused of using excessive force or violating a person’s civil rights under color of law.
Koon does not create a general rule that a defendant’s status as a police officer can justify a downward departure. In United States v. Rybicki, 96 F.3d 754 (4th Cir.1996) the Fourth Circuit considered whether a defendant’s status as a law enforcement officer can, by itself, justify a downward departure based on “disproportionate problems” suffered by incarcerated police officers. See Rybicki, 96 F.3d at 758. That court determined that allowing *486such a general rule suggests that “law enforcement officers, as a class, are entitled to more favorable treatment under the Sentencing Guidelines.” See id. The court found no indication that either Congress or the Sentencing Commission intended to treat law enforcement officers more favorably than other defendants. See id. Therefore, the Fourth Circuit held that a defendant’s mere status as a law enforcement officer cannot justify a downward departure. See id.
Like Rybicki, the district court offered no compelling reasons why Winters is any more susceptible to abuse in prison than any other corrections officer sentenced to prison. Compare United States v. Long, 977 F.2d 1264, 1278 (8th Cir.1992) (allowing departure where defendant’s frail health left him “exceedingly vulnerable to possible victimization and resultant severe and possibly fatal injuries.”) with United States v. Russell, 156 F.3d 687, 694 (6th Cir.1998) (defendant’s deafness did not leave him vulnerable to attack as in Long). Instead, the court determined that Winters’ mere status as an officer justified the departure.
To allow a departure on the basis that Winters is a law enforcement officer would thwart the purpose and intent of the guidelines. See United States v. Kapitzke, 130 F.3d at 822 (allowing departure because child pornographers were susceptible to abuse in prison wbuld thwart the guidelines’ sentences for such crimes). The Sentencing Commission surely considered the possibility that some defendants convicted of violating a persons civil rights under color of law would be law enforcement officers. As noted earlier, the Commission applied greater not lesser sentences for such crimes. Therefore the district court abused its discretion when it departed downward from the guidelines simply because Winters was a law enforcement officer.
Having rejected the district court reasons for a downward departure as expressed in its notice of intent to depart downward, we turn our attention to the dissent’s rejection of our methodology. First, the dissent emphasizes that the district court made its determination based on the totality of the circumstances. Indeed, the dissent recites the phrase “totality of the circumstances” as some mantra which if stated frequently enough will supplant even the district court’s written basis for a departure. Despite the apparent wishes of the dissent, the “totality of the circumstances” is not simply a paradigm which renders the district court’s basis for a downward departure insulated from review of the elements which make up the totality.
A “total” is nothing more than the sum of its component parts. Here, those parts include, inter alia,- Winters’s subjection to a mandatory minimum of five years and his susceptibility to abuse in prison. Again, these are the two reasons articulated in the district court’s notice of intention to consider a downward departure. Individually, neither offers a basis for a downward departure. It is axiomatic that combined they do not offer a basis for departure. Similarly, we find that any derivative from the articulated bases does not offer a basis for departure.3
*487The dissent’s reliance on our recent decision in United States v. Threadgill, 172 F.3d 357 (5th Cir.1999) is mistaken. In Threadgill, the district court articulated two factors which removed this case from the heartland. There, as in the case at bar, the majority accorded substantial deference to the factual determinations of the district court; nevertheless, the majority offered an assessment of the substantive bases for the departure. Based on its analysis, the majority found that Thread-gill “was certainly not a case where the district court disregarded an applicable Guidelines range in favor of another it preferred.” Id., 172 F.3d at 378. Here, the applicable guideline range required a sentence of 108-135 months of imprisonment for violation of 18 U.S.C. § 242 and 1503, to which the mandatory consecutive 60 months imprisonment for the firearms violations under 18 U.S.C. § 924(c) would have been added. See Winters, 105 F.3d at 206. While we do not concern ourselves with the extent of the departure, the record indicates that the district court has failed to articulate a plausible basis for departure. In so doing, the district court impermissibly sentenced Winters to its “preferred” sentence of 12 months for a second time.
B. Reassignment to a Different Judge
Finally, the government urges this court to reassign this case to a different district judge on remand. A federal court of appeals has the supervisory authority to reassign a case to a different trial judge on remand. See Johnson v. Sawyer, 120 F.3d 1307 (5th Cir.1997); 28 U.S.C. § 2106. However, this is an extraordinary power and should rarely be invoked. See id. Such reassignments “should be made infrequently and with the greatest reluctance.” In re Corrugated Container Antitrust Litigation: Adams Extract Co. v. Green Pay Packaging, 752 F.2d 137 (5th Cir.1985) (quoting Koller v. Richardson-Merrell, 737 F.2d 1038, 1067 (D.C.Cir.1984) (Richey, J., concurring)).
This Circuit has not decided which of two tests should be used to decide whether to reassign a case. See Johnson, 120 F.3d at 1333. Several circuits will reassign a case to avoid bias or the appearance of bias. See id. The Ninth and Tenth Circuits, however, have adopted a more formal test, which requires the court to consider three factors:
(1) whether the original judge would reasonably be expected upon remand to have substantial difficulty in putting out of his or her mind previously-expressed views or findings determined to be erroneous or based on evidence that must be rejected, (2) whether reassignment is advisable to preserve the appearance of justice, and (3) whether reassignment would entail waste and duplication out of proportion to any gain in preserving the appearance of fairness. Johnson, 120 F.3d at 1333, citing Davis & Cox v. Summa Corp., 751 F.2d 1507, 1523 (9th Cir.1985) (quoting United States v. Robin, 553 F.2d 8, 10 (2d Cir.1977)).
See also United States v. White, 846 F.2d 678, 695-96 (suggesting three-prong test should be used where there is no direct evidence of bias).
This case does not call for reassignment under either test. No showing has been made that we are presented with a case of bias or antagonism toward one party in the *488case. Contra, Johnson, 120 F.3d 1307 (reassigning case where lower court made repeated antagonistic remarks and admitted hostility towards IRS). Although the district court twice chose to depart downward from Winters’ sentence, it made no indication that it would refuse to impartially weigh evidence and decide the matters before it objectively.
Moreover, the fact that this court has already reversed the district court does not necessarily require reassignment. In United States v. O’Brien, this court faced a procedurally similar situation. See O’Brien, 18 F.3d at 302. There, the district court had imposed a sentence which this Court later vacated. See id. Upon remand, the district court again imposed an improper sentence. See id. On the second appeal, one of the parties urged this court to reassign the case. See id. at 303-304. This Court refused to do so. “The district judge will, we are confident, perform his duty. It is unseemly for us to either assume that he will take a particular course or to suggest what he should do so long as he reaches a decision in accordance with the controlling statutes.” ' See id., quoting United States v. Denson, 603 F.2d 1143, 1149 (5th Cir.1979). See also United States v. Schoenhoff, 919 F.2d 936 (5th Cir.1990) (“We refuse to transfer an action for re-sentencing solely because two prior sentences imposed by the trial court have been reversed.”). We decline the government's invitation to reassign this case.
Conclusion
For the reasons stated herein, we VACATE Winter’s sentence and REMAND to the district court for re-sentencing.
. The dissent chides the majority for failing to give substantial deference to the district court judge who presided over the trial and has "extensive judicial service and experience, especially in matters regarding the penitentiary.” The dissent’s emphasis on the trial judge's experience amounts to the proverbial red herring. The vast experience and legal acumen of the district judge is beyond dispute and nothing in the majority's opinion suggests otherwise.
We simply part company with the dissent's notion that a district judge’s sentencing decisions are virtually impervious from appellate review. Substantial deference has never been synonymous with carte blanche approval of a sentencing judgment in the face of legal error. Indeed, when reviewing tire basis for a downward departure, our function as a court of appeals would be rendered superfluous if "substantial deference” operated as a talisman designed to ward off the scrutiny of this court.
. See id., Application Note 4.
"Where there is also a conviction for the underlying offense, a consolidated fine guideline is determined by the offense level that would have applied to the underlying offense absent a conviction 18 U.S.C. § 844(h), § 924(c), or § 929(a). This is required because the offense level for the underlying offense may be reduced when there is also a conviction under 18 U.S.C. § 844(h), § 924(c), or § 929(a) in that any specific offense characteristic for possession, use, or discharge of a firearm is not applied....”
. For example, the dissent highlights the reasons the district court found Winters susceptible to abuse. We reject the same because all relate to Winters’ status as a correctional officer and nothing in the record indicates that Winters is unique among other inmates who were formerly correctional officers or police officers. The dissent's attempt to minimize the effect of the Federal Bureau of Prisons letter confirming that it is fully capable of housing Winters exposes the futility of its argument.
The dissent hypothesizes that the Federal Bureau of Prisons could have produced a similar letter in Koon yet the Supreme Court found that susceptibility to abuse should be considered. Nothing in Koon indicates the existence of any such letter; therefore, it is equally plausible that no letter existed. Yet, we need not engage in such conjecture regarding the facts in Koon because there is little doubt that the facts surrounding the violation of Rodney King’s civil rights re*487ceived far greater exposure than Winters's violation of Lariy Floyd's. In fact, despite the dissent’s emphasis on the publicity surrounding this case, nothing in the record bears upon the nature and extent of any such publicity.
Furthermore, while the publicity in Koon introduced a measure of complexity in safely housing the defendants in any federal facility, the relative paucity of publicity in this case precludes us from finding a comparative measure of complexity. Winters spent 15 years working in a penitentiary in Mississippi and was imprisoned in Minnesota. By emphasizing Winter's status as a corrections officer, the dissent impermissibly lowers the bar for corrections officers.