United States v. Wilson, Sonni

                  United States Court of Appeals

               FOR THE DISTRICT OF COLUMBIA CIRCUIT

       Argued November 9, 2000   Decided February 23, 2001 

                           No. 99-3077

                    United States of America, 
                             Appellee

                                v.

                          Sonni Wilson, 
                            Appellant

          Appeal from the United States District Court 
                  for the District of Columbia 
                        (No. 96cr00362-01)

     Stephen C. Leckar, appointed by the court, argued the 
cause and filed the briefs for appellant.

     Sonni I. Wilson, appearing pro se, was on the briefs for 
appellant.

     Mary B. McCord, Assistant U.S. Attorney, argued the 
cause for appellee.  With her on the brief were Wilma A. 

Lewis, U.S. Attorney, John R. Fisher, Mary-Patrice Brown 
and Ann M. Carroll, Assistant U.S. Attorneys.

     Before:  Williams and Garland, Circuit Judges, and 
Silberman, Senior Circuit Judge.

     Opinion for the Court filed by Circuit Judge Williams.

     Opinion by Circuit Judge Garland concurring in part and 
dissenting in part.

     Williams, Circuit Judge:  A jury in district court convicted 
Sonni Wilson of bank fraud and other related offenses.  The 
evidence at trial revealed two separate schemes--one in 1996 
targeting several banking institutions including the First 
Bank Card Center and one in 1997/98 targeting First Nation-
al Bank of Maryland.  In both, Wilson fraudulently procured 
and used credit cards, ATM cards, check cards and checks 
issued in other people's names.  In some cases he accom-
plished his fraud by opening entirely new accounts, while in 
others he supplied confidential personal information about 
actual account holders to fraudulently gain control of their 
accounts.  For any one account, the fraud was necessarily 
short-lived:  Use of an actual account would quickly trigger 
reaction either by the true holder or by bank personnel on 
the alert for suspicious activity such as unusually large cash 
withdrawals;  use of fictional accounts would be exposed by 
suspicious account activity or by non-payment of the bill.

     Wilson was first arrested in 1996 after bank investigators 
alerted the police.  After indictment, he jumped bail.  Follow-
ing a new arrest in 1998, he was charged with six counts of 
bank fraud (18 U.S.C. s 1344), one count of possession of 15 
or more unauthorized access devices1 with intent to defraud 
(18 U.S.C. s 1029(a)(3)), one count of conspiracy to commit 
bank fraud and to possess 15 or more unauthorized access 
devices with intent to defraud (18 U.S.C. s 371), and one 
count of possession of five or more false identification docu-
ments with intent to use illegally (18 U.S.C. s 1028(a)(3)).  

__________
     1  18 U.S.C. s 1029(e)(1) defines "access device[s]" as cards or 
other "means of account access" that can be used to obtain money, 
etc., or initiate a transfer of funds.

The jury convicted Wilson on all counts, and the district court 
sentenced him to 51 months' imprisonment followed by three 
years of supervised release.

     On appeal Wilson challenges several aspects of his convic-
tion and sentencing.  Because of an error in sentencing, we 
reverse.

                              * * *

     Effect on commerce of Wilson's possession of access de-
vices.  18 U.S.C. s 1029(a), which prohibits various forms of 
access device fraud, applies only "if the offense affects inter-
state or foreign commerce."  Wilson first argues that under 
United States v. Lopez, 514 U.S. 549 (1995), he can be held 
criminally accountable under federal law only if the govern-
ment proves that his actions had a "substantial" effect on 
interstate commerce.  But we have already held, since Lopez, 
that to support a statutory jurisdictional link for a specific 
criminal act it is enough that the evidence show that the act 
had "an 'explicit' and 'concrete' effect on interstate commerce, 
rather than a 'substantial' one."  United States v. Harring-
ton, 108 F.3d 1460, 1465 (D.C. Cir. 1997).  In Harrington, we 
upheld a conviction on the basis of evidence that defendant's 
robbery of a Roy Rogers restaurant deprived the restaurant 
of money that would have traveled to an out-of-state bank and 
then been used by the Roy Rogers parent company in part to 
make out-of-state purchases.  See id. at 1468.

     Wilson also offers a second, independent argument that the 
evidence failed to show that the access card offenses had any 
effect at all on interstate commerce.  The government con-
cedes that Wilson properly preserved this argument by mak-
ing a motion for judgment of acquittal after the government 
rested.  Because Wilson presented no defense at all, his 
motion at the end of the government's case fully preserved 
his claim.  See United States v. Foster, 783 F.2d 1082, 1085 
(D.C. Cir. 1986);  see also United States v. Sherod, 960 F.2d 
1075, 1077 (D.C. Cir. 1992).  We review de novo the denial of 
the motion to determine whether the evidence, considered in 
the light most favorable to the government, was "sufficient to 

permit a rational trier of fact to find all of the essential 
elements of the crime beyond a reasonable doubt."  Harring-
ton, 108 F.3d at 1464.

     Wilson's claim is meritless.  His only argument for insuffi-
ciency is that an expert witness's general testimony regarding 
the losses suffered by banks as a result of similar fraudulent 
schemes was not specific enough to establish that Wilson's 
deeds affected interstate commerce.  But the government 
points to a great deal of other evidence that speaks to the 
interstate commercial effect of Wilson's fraud.  There is, in 
fact, evidence of interstate impact for all 16 of the devices 
charged in the indictment.

     Of these devices, three are armed services MasterCards 
that Wilson applied for in 1996 through Andrews Air Force 
Base in Maryland, causing them to be issued by the First 
Card Bank Center in Louisiana, and sent to Washington, D.C.  
Regarding the 1997/98 scheme, 12 access devices serviced 
accounts that Wilson fraudulently opened via phone calls to a 
bank center in North Carolina but were handled by a Wash-
ington, D.C. branch office.  (For several of these Wilson used 
a Maryland address, and for several of those with a Maryland 
address he used identities of persons located in states other 
than the District or Maryland).  Finally, the remaining device 
is a Sears Card issued in the name of a California resident 
and found in Wilson's wallet when he was arrested in Wash-
ington, D.C.  Although Wilson evidently lived in Washington, 
he used this card in Maryland and provided a Maryland 
address for the account.  The jury could reasonably find the 
modest interstate effect required under Harrington.

     Failure to instruct jury on need to find interstate nexus 
for false ID conviction.  Conviction under 18 U.S.C. s 1028 
for possession of five or more false identification documents, 
with intent to use unlawfully, requires that the government 
satisfy the requirement of s 1028(c)(1) that the possession be 
"in" or "affect" interstate commerce.  The government con-
cedes that the trial judge failed to instruct the jury on the 
need for such a finding.  And Wilson concedes that because of 
his failure to object at trial the error would be grounds for 

reversal only if it amounted to plain error under Rule 52(b) of 
the Federal Rules of Criminal Procedure.2  As the Supreme 
Court explained in United States v. Olano, 507 U.S. 725 
(1993), Rule 52(b) requires that there "be an error that is 
plain and that affect[s] substantial rights.  Moreover, Rule 
52(b) leaves the decision to correct the forfeited error within 
the sound discretion of the court of appeals, and the court 
should not exercise that discretion unless the error seriously 
affect[s] the fairness, integrity, or public reputation of judicial 
proceedings."  Id. at 732 (internal quotations omitted).

     The Supreme Court's holding in United States v. Gaudin, 
515 U.S. 506 (1995), strongly suggests there was an error and 
that it was "plain."  The Court held that the Fifth and Sixth 
Amendments require that all elements of a crime be submit-
ted to the jury, with the only conceivable exception being for 
issues involving a "uniform postratification practice" to the 
contrary.  Id. at 519.  The government invokes no such 
practice.  But we need not conclusively determine the issue, 
as Wilson has failed to show that the alleged error affected 
"substantial rights."

     In his opening brief, Wilson argued summarily that the 
defective instruction affected substantial rights and was 
"prejudicial":  "It invited the jury to convict without finding 
whether Appellant's conduct had been in or affected inter-
state commerce.  There is no reason to believe that the jury 
disregarded that invitation."  Appellant's Main Brief at 29.  
This simple treatment would have been adequate if omission 
of an essential element of the crime were a "structural" error, 
such as "complete deprivation of counsel or trial before a 
biased judge," which is automatically deemed to affect sub-
stantial rights.  Neder v. United States, 527 U.S. 1, 8-9 
(1999).  But Neder holds that failure to instruct on an ele-
ment of the crime is not structural.  Where, as in Neder, 
objection has been made, omission of an element of the crime 
from the instructions is reviewed for harmless error, id. at 8-

__________
     2  Rule 52(b) provides that "[p]lain errors or defects affecting 
substantial rights may be noticed although they were not brought to 
the attention of the court."

15, so that (the error being of constitutional magnitude) the 
verdict can be upheld if the government shows " 'beyond a 
reasonable doubt that the error complained of did not contrib-
ute to the verdict obtained.' "  Id. at 15 (quoting Chapman v. 
California, 386 U.S. 18, 24 (1967)).  Olano explains that for 
plain error review the burden on prejudice is reversed, re-
quiring the defendant to show the error's likely effect on the 
verdict.  507 U.S. at 734.  Wilson made no effort whatever to 
carry that burden.  Thus the government was on solid ground 
in reading his brief as claiming only structural error.  As the 
alleged error was not structural, Wilson has failed to offer 
support for a key ingredient of his claim, which thus neces-
sarily fails.

     We are not diverted from this conclusion by the fact that 
the government's brief, in a backup passage addressing the 
final element of plain error (whether the error affected "the 
fairness, integrity or public reputation of judicial proceed-
ings," see Olano, 507 U.S. at 732), included a summary 
collection of evidence on interstate impact.  First, as this was 
offered for a purpose different from the issue of actual 
impact, the government could fairly suppose that different 
standards were applicable.  Second, we are doubtful in any 
event whether gilding the lily in the appellee's brief should 
ever excuse an appellant's complete failure to support a 
necessary ingredient of a claim.  Similarly, of course, Wil-
son's effort in his reply brief to meet his burden of showing 
prejudice comes too late.  McBride v. Merrell Dow and 
Pharmaceuticals, Inc., 800 F.2d 1208, 1210 (D.C. Cir. 1986);  
see also Carducci v. Regan, 714 F.2d 171, 177 (D.C. Cir. 
1983).

     Alleged prosecutorial "vouching" for a witness's credibility.  
Wilson argues that his conviction should be overturned be-
cause the prosecutor, during closing argument, improperly 
vouched for the credibility of an Inspector Bartlett, who had 
investigated and arrested Wilson in both 1996 and 1998 and 
who obtained a confession from him after the 1998 arrest.  
Although Wilson does not actually identify any specific state-
ment, the target of his complaint appears to be the second 
half of the prosecutor's claim that "there is no evidence to 

support any of those allegations [against Bartlett] and, if it 
[sic] was, we would not be here."  Trial Transcript (June 15, 
1998) at 70.  The context of the statement was the defense 
attorney's suggestion, as the climax of his closing argument, 
that because of racial bias Bartlett had not only manufactured 
the confession but somehow tainted (or perhaps even manu-
factured) "[t]his case, and all of this evidence."  Id.

     We need not decide whether, given this provocation, there 
was any error in the trial court's failure to act on the 
prosecutor's response.  Wilson has shown no impact on "sub-
stantial rights," which Olano requires and here means a 
demonstration of prejudice.  To judge the prejudicial effect of 
a closing argument error we look to the severity of the 
alleged misconduct, the centrality of the issue affected by the 
error, the steps taken to mitigate the error, and the closeness 
of the case.  See United States v. Gartmon, 146 F.3d 1015, 
1026 (D.C. Cir. 1998).  Wilson makes no effort to show how 
the prosecution's single offhand remark could have been a 
severe error.  Cf. id. at 1026 (" 'Without other compelling 
factors, a single misstatement confined to a closing argument 
rarely amounts to severe misconduct.' ").  While Bartlett's 
account of Wilson's statement and Bartlett's role in authenti-
cation of the fraudulent credit cards and IDs made him an 
important witness, Wilson's guilt was critically proven by the 
documents themselves, and the testimony of several victims, 
bank fraud investigators, and co-conspirator Clarence Terrell.  
Wilson concedes that the court gave the standard limiting 
instructions that the lawyers' arguments are not evidence, 
and we have found that such instructions "mitigate the impact 
of erroneous jury argument."  Id. at 1026.  Finally, the case 
was not particularly close.  We find no prejudice, and thus no 
plain error.

     Effectiveness of counsel.  In a pro se brief Wilson asserts 
that trial counsel was ineffective.  We do not normally resolve 
such claims when raised initially on appeal, unless "the record 
is so clear that remand is unnecessary."  United States v. 
Soto, 132 F.3d 56, 59 (D.C. Cir. 1997).  As Wilson's claims are 
vague and conclusory, or based on assertions of admissions by 
counsel that are plainly not admissions of any ineffectiveness, 

they do not meet that standard.  Pursuant to our usual 
practice, we remand the issue for consideration by the trial 
court.

     Enhancement of sentence for obstruction of justice.  Wil-
son says that the court erred by imposing a two-level en-
hancement for obstruction of justice, under U.S.S.G. s 3C1.1, 
based upon a finding that Wilson committed perjury at a 
suppression hearing.  The court found two separate perju-
ries.  Either would be sufficient, so we need resolve Wilson's 
(failing) attack on only one.

     At the suppression hearing Wilson falsely denied that he 
was the man depicted in a photograph shown to him at the 
hearing.  He says that the question was not material to the 
subject of the hearing, which focused on the voluntariness of 
Wilson's post-arrest confession.  Materiality is indeed essen-
tial, see United States v. Dunnigan, 507 U.S. 87, 94 (1993), 
but Wilson's claim is specious.  The government presented 
evidence that at his arrest Wilson claimed to be "Imione 
Wilson," that he signed a waiver of his Miranda rights as 
"Imione Wilson," and that a driver's license bearing that 
name was found in his residence.  Wilson denied that he had 
signed such a waiver and that he was Imione Wilson.  When 
presented with the Imione Wilson driver's license, he denied 
that he was the person depicted in the photo on the card.  
His denial was clearly material to whether or not he had 
signed the waiver, and thus to whether or not his confession 
had been voluntary.

     Sentence enhancement under U.S.S.G. s 3B1.1(a).  Section 
3B1.1(a) of the United States Sentencing Guidelines allows 
for a four-level upward adjustment in the base offense level 
"[i]f the defendant was an organizer or leader of a criminal 
activity that involved five or more participants or was other-
wise extensive." Wilson argues that the trial court erred both 
when it determined he was an "organizer or leader," and also 
when it found the relevant criminal activity was "otherwise 
extensive."

     When reviewing the district court's application of the 
Guidelines, "purely legal questions are reviewed de novo;  

factual findings are to be affirmed unless 'clearly erroneous';  
and we are to give 'due deference' to the district court's 
application of the guidelines to facts."  United States v. Kim, 
23 F.3d 513, 517 (D.C. Cir. 1994);  see 18 U.S.C. s 3742(e).

     In finding that Wilson was an "organizer or leader of a 
criminal activity," the district court relied heavily on the 
testimony of Clarence Terrell, a former bank teller at First 
National.  Terrell testified that he assisted Wilson's fraudu-
lent scheme by providing him with names and confidential 
information regarding account holders.  The court found that 
Wilson "solicited Mr. Terrell's involvement" in the criminal 
conduct, and gave him "very explicit directions as to exactly 
the kind of information, and exactly the kind of profile that he 
wanted Mr. Terrell to get out of the bank's records."  Sen-
tencing Transcript (June 10, 1999) at 56.  In addition, the 
court found that "Mr. Terrell himself received extremely little 
gain from the entire scheme, and Mr. Terrell had no decision 
making role or authority in the criminal activity."  Id.

     Wilson attacks these findings, mainly on the ground that 
they do not address his "control" of Terrell.  We need not 
attempt an exegesis of the concept of control.  Cf. United 
States v. Kelley, 36 F.3d 1118, 1129 (D.C. Cir. 1994).  The 
exercise of decisionmaking authority, recruitment, and a 
claimed right to a larger share of the proceeds are prominent 
among the factors that the commentary to the Guidelines 
indicates should be considered.  See U.S.S.G. s 3B1.1, Appli-
cation Note 4.  Given that the trial court's findings accurately 
reflect Terrell's trial testimony, the court's determination 
easily meets the "due deference" standard.

     Although the finding that Wilson was an organizer or 
leader of criminal activity is itself enough to justify a two-
point enhancement under s 3B1.1(c), Wilson's four-point en-
hancement under s 3B1.1(a) is contingent on the additional 
finding that the criminal activity Wilson organized or led 
involved "five or more participants, or was otherwise exten-
sive."  "Participants," for these purposes, explicitly include 
only persons "criminally responsible for the commission of the 
offense."  s 3B1.1, Application Note 1.  At sentencing, the 

court conceded that "there may be some question in the 
evidence as to whether five or more participants were actually 
clearly established," but found the criminal activity "other-
wise extensive," declaring that "there is no question in the 
court's mind on the basis of ... evidence presented at trial 
... that this was a many layered scheme that was an 
extraordinarily extensive scheme to defraud people of their 
monies."  Sentencing Transcript (June 10, 1999) at 55-56.

     Wilson asserts that the district court's concept of "other-
wise extensive" was incorrect, and that to make such a 
finding the court must look primarily or solely to the number 
of persons involved in the criminal activity, criminally or 
noncriminally, as did the Second Circuit in United States v. 
Carrozzella, 105 F.3d 796, 802 (2d Cir. 1997).  We agree.

     The circuits are currently split on the factors relevant to an 
activity's being "otherwise extensive."  The Third Circuit has 
recently adopted the Carrozzella test.  See United States v. 
Helbling, 209 F.3d 226, 244-45 (3rd Cir. 2000).  On the other 
side the leading case is United States v. Dietz, 950 F.2d 50, 53 
(1st Cir. 1991), which reads the Guidelines as imposing first 
an "irreducible minimum" requirement that the defendant be 
involved in criminal activity with at least one other criminally 
responsible person,3 but, once this is met, as directing the 
court to plunge into an unconstrained inquiry into the scale of 
the activity.  Thus, under Dietz, the court looks to "the 
totality of the circumstances, including not only the number of 
participants but also the width, breadth, scope, complexity, 
and duration of the scheme."  Id.  The Tenth Circuit has 
expressly endorsed the Dietz test, see United States v. Yar-
nell, 129 F.3d 1127, 1139 (10th Cir. 1997), and others have 
similarly looked to a broad range of factors beyond the 
number of persons involved, see, e.g., United States v. Tai, 41 
F.3d 1170, 1174-75 (7th Cir. 1994);  United States v. Rose, 20 

__________
     3  It is unclear whether the Second Circuit has any such mini-
mum requirement of a single guilty coparticipant.  Given the find-
ings on Terrell, we need not consider whether such a finding is 
necessary.

F.3d 367, 374 (9th Cir. 1994);  United States v. Mergerson, 4 
F.3d 337, 348 (5th Cir. 1993).

     We think the Second and Third Circuits have the better 
case.  It is true that the text of s 3B1.1(a) says nothing about 
what factors render criminal activity "extensive."  But the 
Sentencing Commission's Commentary focuses solely on the 
role of unknowing actors:  "In assessing whether an organiza-
tion is 'otherwise extensive,' all persons involved during the 
course of the entire offense are to be considered.  Thus, a 
fraud that involved only three participants but used the 
unknowing services of many outsiders could be considered 
extensive."  U.S.S.G. s 3B1.1, Application Note 3.

     Our dissenting colleague correctly notes that the commen-
tary does not expressly state that the number of persons is 
the "only" relevant factor, see Dissent at 4, but then relies on 
other language in the commentary to support a broader 
interpretation of the phrase "otherwise extensive":

          In relatively small criminal enterprises that are not 
     otherwise to be considered as extensive in scope or in 
     planning or preparation, the distinction between organi-
     zation and leadership, and that of management or super-
     vision, is of less significance than in larger enterprises 
     that tend to have clearly delineated divisions of responsi-
     bility.  This is reflected in the inclusiveness of 
     s 3B1.1(c).
     
U.S.S.G. s 3B1.1, Background (emphasis added);  see Dissent 
at 4-5.

     While we agree that the reference to "scope," "planning," 
and "preparation" is somewhat confusing, in context the 
sentence ultimately supports our reading of s 3B1.1.  The 
immediately preceding paragraph of the commentary explains 
that s 3B1.1 "provides a range of adjustments to increase the 
offense level based upon [1] the size of a criminal organization 
(i.e., the number of participants in the offense) and [2] the 
degree to which the defendant was responsible for the of-
fense."  Id. (emphasis and numbers added).  The language at 
issue here, whether a criminal activity "involved five or more 
participants or was otherwise extensive," s 3B1.1(a),(b), 
plainly relates only to the first factor--"size."  Although the 

commentary does not explicitly discuss the "otherwise exten-
sive" prong, the explicit identification of "size" with "number 
of participants" reinforces the impression that the language is 
concerned with the number of people involved in the offense.  
On the other hand, s 3B1.1 addresses the second factor, 
degree of responsibility, by providing enhancement only for 
the criminal who is either an "organizer or leader" (subsec-
tion (a)) or "a manager or supervisor" (subsection (b)).

     The paragraph emphasized by the dissent addresses a 
particular aspect of how s 3B1.1 treats these two basic 
factors.  Subsections (a) and (b) cover the cases where the 
activity "involved five or more participants or was otherwise 
extensive," giving the "organizer or leader" a four-level en-
hancement, and the "manager or supervisor" only a three-
level one.  But when the size factor is not satisfied, s 3B1.1(c) 
applies a uniform two-level enhancement to the "organizer, 
leader, manager, or supervisor," drawing no distinction be-
tween these types of responsibility.  The language quoted 
explains the interaction by noting that "the distinction be-
tween organization and leadership, and that of management 
or supervision" is of "less significance" in the case of "rela-
tively small criminal enterprises that are not otherwise to be 
considered as extensive in scope or in planning or prepara-
tion."  s 3B1.1, Background (emphasis added).  By contrast, 
the distinction is more significant in the case of "larger 
organizations that tend to have clearly delineated divisions of 
responsibility."  Id. (emphasis added).

     Thus, rather than suggest that scope, planning and prepa-
ration actually define an organization as large or small, the 
commentary merely conveys the point that organizations that 
are larger tend to be of broader scope and involve more 
planning and preparation than those that are smaller, and 
that, for this reason, it is appropriate to distinguish between 
types of responsibility in larger organizations to an extent not 
necessary in the case of smaller ones.  Far from defining 
whether or not a criminal activity is "otherwise extensive," 
the cited factors are relevant to decide the entirely separate 
question of degree of responsibility.  As the commentary 
states elsewhere, "[i]n distinguishing a leadership and organi-

zational role from one of mere management or supervision" 
the court should consider factors such as "the degree of 
participation in planning or organizing the offense" and "the 
nature and scope of the illegal activity."  Id. at Application 
Note 4.

     The court in Carrozzella also reasoned that an open-ended 
approach invited double counting:

     Many characteristics that might ordinarily be considered 
     evidence of 'extensive' activity are dealt with elsewhere 
     in the Guidelines.  For example, in fraud cases, the base 
     offense level can be raised according to the amount of 
     loss, the extent of planning, and the number of victims.  
     [U.S.S.G] s 2F1.1.  Further adjustments can be made 
     according to the vulnerability of the victim, s 3A1.1, the 
     defendant's role, ss 3B1.1, 3B1.2, and abuse of a position 
     of trust, s 3B1.3.
     
105 F.3d at 802.

     While our dissenting colleague correctly points out that the 
Guidelines' key distinction for double counting is between 
permissible and impermissible, see Dissent at 5-6, the cited 
case, United States v. Valdez-Torres, 108 F.3d 385, 389 (D.C. 
Cir. 1997), holds simply that the prospect of double counting 
does not allow a court to "ignore the plain language of the 
Guidelines."  Id.  That is not inconsistent with joining the 
Second Circuit in taking duplication into account in the 
construction of an ambiguous phrase such as "otherwise 
extensive."

     Of course, a court could address the concern for impermis-
sible double counting by finding extensiveness only in charac-
teristics (besides the number of actors) not adequately taken 
into account elsewhere in the Guidelines.  But the Sentencing 
Reform Act expressly contemplates enhancement for such 
omissions or underassessments, allowing the sentencing court 
to depart from the otherwise applicable range if "the court 
finds that there exists an aggravating or mitigating circum-
stance of a kind, or to a degree, not adequately taken into 
consideration by the Sentencing Commission in formulating 

the guidelines that should result in a sentence different from 
that described."  18 U.S.C. s 3553(b);  see generally Koon v. 
United States, 518 U.S. 81, 91-96 (1996).  So it seems proba-
ble that any straying beyond the number of persons involved 
would at best create two headings under which these extras 
would be considered, and at worst cause unauthorized double 
counting.

     The government suggests that we have already implicitly 
rejected the Second Circuit view, pointing to United States v. 
Sobin, 56 F.3d 1423, 1428 (D.C. Cir. 1995), and United States 
v. Dale, 991 F.2d 819, 857 (D.C. Cir. 1993).  In Sobin, we did 
rely on factors other than head count to uphold an "otherwise 
extensive" determination, but in that case the defendant 
challenged only the factual findings, not the legal standard.  
56 F.3d at 1428.  Dale similarly did not involve a conflict as to 
the standard, and in fact the trial court had found at least five 
persons involved.  991 F.2d at 857.  Thus we are free to 
adopt, and do adopt, the view of the Second Circuit that 
s 3B1.1(a) is "not so much about extensiveness in a colloquial 
sense as about the size of the organization in terms of persons 
involved that a defendant 'organize[d]' or 'le[d].' "  Carrozzel-
la, 105 F.3d at 803.

     We further agree with the Second Circuit that, at a mini-
mum, " 'Section 3B1.1's 'otherwise extensive' prong demands 
a showing that an activity is the functional equivalent of an 
activity involving five or more participants.' "  Id. at 803 
(quoting United States v. Tai, 41 F.3d 1170, 1174 (7th Cir. 
1994)).  To read the "otherwise extensive" prong as a lesser 
requirement would either allow this provision to eat up the 
"five or more participant" prong or would produce the anoma-
lous result that unknowing outsiders count more than crimi-
nally culpable participants.  See id.  A necessary implication 
of this analysis is that the number of persons involved must 
total at least five, as it is hard to see how any lesser number 
could constitute the functional equivalent of five or more 
knowing participants.  But what is necessary may not always 
be enough.4  In Carrozzella the Second Circuit observed that 

__________
     4  On the facts of this case, we need not explore whether on a 
rare occasion the innocent actor might be found more effective than 

the use of "unknowing participants"5 may be "less efficient" 
than the use of knowing participants or "may still only 
minimally further the criminal activity."  105 F.3d at 804.  
Cf. Tai, 41 F.3d at 1174-75 ("If a district court intends to rely 
solely upon the involvement of a given number of individuals 
to support a determination that criminal activity is 'otherwise 
extensive,' it must point to some combination of participants 
and outsiders equaling a number greater than five.").  To 
ensure that the "extent of harm and degree of culpability in 
organizing or leading five unknowing participants" is not less 
than in case of knowing participants, Carrozzella permits the 
sentencing court to "take into account the role and perfor-
mance as well as the number of unknowing participants." 105 
F.3d at 804 (emphasis added).

     There remains the issue of who should be counted once we 
include those who are unknowing or otherwise not criminally 
involved.  Indeed, the government claims that Wilson's en-
hancement is justified even under the Carrozzella framework.  
The Second Circuit considered the problem, noting as an 
example that it was necessary to distinguish the "taxi driver 
who brought a leader of the fraudulent scheme to work on a 
single occasion" from the "[s]alespeople who unknowingly 
conveyed fraudulent misrepresentations at a defendant's re-
quest."  Id.  The court identified the following factors as 
relevant to the head count:

     (i) the number of knowing participants;  (ii) the number 
     of unknowing participants whose activities were orga-
     
__________
knowing participants, perhaps because his ignorance of the scheme 
made him less nervous or otherwise improved his plausibility.  Nor 
need we consider whether there should be some presumptive rate of 
substitution between the types of actors (e.g., one participant 
presumptively equals two outsiders).

     5  Although the Guidelines define the word "participant" solely 
in terms of criminally culpable actors, see U.S.S.G. s 3B1.1., Appli-
cation Note 1, the Second Circuit, at the risk of some confusion, has 
adopted the term "unknowing participants" to describe those "out-
siders" contemplated in the commentary to the Guidelines.  Carroz-
zella, 105 F.3d at 803-804;  see also U.S.S.G. s 3B1.1., Application 
Note 3.

     nized by or led by the defendant with specific criminal 
     intent [as opposed to mere service providers];  and (iii) 
     the extent to which the services of the unknowing partici-
     pants were peculiar and necessary to the criminal 
     scheme [rather than fungible with others generally avail-
     able to the public].
     
Id. at 803-804.  We agree that these criteria are relevant.

     In trying to fit the present case under Carrozzella, the 
government claims that "[d]ozens of 'unknowing participants' 
were involved, carrying out [Wilson's] bogus directions to 
open accounts and change addresses without realizing that 
[Wilson] was not who he claimed to be."  Appellee's Brief at 
47.  In the government's view, the role of these "unnamed 
bank employees" is analogous to that of the hypothetical 
salespeople mentioned in Carrozzella, who convey fraudulent 
misrepresentations on behalf of the defendant.

     But even if we assume that the activities of the various 
bank personnel invoked by the government were "peculiar 
and necessary" to Wilson's scheme, we do not see how they 
could be described as "organized or led" by him.  The bank 
employees who changed account addresses and issued credit 
cards on Wilson's instructions were, so far as appears, simply 
performing routine tasks that, according to pre-established 
bank policies, followed automatically once Wilson provided 
the necessary information.  Such automatic behavior by func-
tionaries of a victim institution appears totally different from 
the salesmanship of people retained by the defendant to 
market and sell a product with representations that, unbe-
knownst to the agent, are false.  To hold otherwise would risk 
the absurdity that a defendant who procured 10 different 
credit cards on 10 different days would escape upward adjust-
ment if the same telephone operator happened to receive his 
request each time, whereas an otherwise identical defendant 
would get the enhancement solely because each of his calls 
connected him to a new employee.  To take the government's 
logic one step further, upward adjustment might turn on the 
complexity of a bank's internal bureaucracy, with the count of 

unknowing participants determined by the number of desks 
over which a fraudulent request must pass.

     The government alternatively suggests, presumably as a as 
a matter of common sense, that we can infer that Wilson must 
have used a number of additional knowing confederates.  But 
it does not point to evidence of bank operations from which 
we (or the district court) could reasonably draw such an 
inference.

     Finally, we note that in United States v. Nolan, 136 F.3d 
265, 273 (2d Cir. 1998), the Second Circuit applied the Carroz-
zella test without discussion of whether the unknowing partic-
ipants were in any way organized or led by the defendant.  
Of course we cannot say whether this foreshadows a Second 
Circuit retreat from Carrozzella, but in any event we think 
Carrozzella got it right.

     Accordingly, we see no basis for the four-point enhance-
ment under s 3B1.1(a).  We vacate the sentence and remand 
the case for further proceedings consistent with this decision.  
As noted earlier, we remand the claim of ineffective assis-
tance of counsel.  The conviction is otherwise affirmed.

                                                            So ordered.

     Garland, Circuit Judge, concurring in part and dissenting 
in part:

     I concur in the court's affirmance of defendant Wilson's 
conviction and of his sentence enhancement for obstruction of 
justice.  I differ only in that I would also affirm the district 
court's decision to increase Wilson's sentence under 
s 3B1.1(a), for his role as the leader of a criminal activity that 
was "otherwise extensive."  My colleagues hold that "other-
wise extensive" should be defined solely by the number of 
persons involved in the activity.  Op. at 14.  In so doing, they 
follow the lead of two circuits,1 but reject the views of eight 
others, all of which look to factors beyond a simple head-
count.2  This circuit, too, has looked to such other factors, 
although, as the court notes, in those cases the legal question 
now before us was not squarely raised.3  Because I conclude 
__________
     1  See United States v. Helbling, 209 F.3d 226, 244-45 (3d Cir. 
2000);  United States v. Carrozzella, 105 F.3d 796, 802-04 (2d Cir. 
1997).

     2  See, e.g., United States v. Dietz, 950 F.2d 50, 53 (1st Cir. 1991) 
("[T]he extensiveness of a criminal activity is not necessarily a 
function of the precise number of persons, criminally culpable or 
otherwise, engaged in the activity.  Rather, an inquiring court must 
examine the totality of the circumstances, including not only the 
number of participants but also the width, breadth, scope, complexi-
ty, and duration of the scheme.");  United States v. Mergerson, 4 
F.3d 337, 348 (5th Cir. 1993);  United States v. Sanders, 95 F.3d 
449, 457 (6th Cir. 1996);  United States v. Tai, 41 F.3d 1170, 1175 
(7th Cir. 1994);  United States v. Morphew, 909 F.2d 1143, 1145 (8th 
Cir. 1990);  United States v. Rose, 20 F.3d 367, 374 (9th Cir. 1994);  
United States v. Yarnell, 129 F.3d 1127, 1139 (10th Cir. 1997);  
United States v. Rodriguez, 981 F.2d 1199, 1200 (11th Cir. 1993).  
As the court notes, the First Circuit reads the Guidelines as also 
requiring, as an irreducible minimum, that the activity involve at 
least one criminally responsible person in addition to the defendant.  
See Dietz, 950 F.2d at 53.  Although I agree that we need not 
decide that point in order to resolve this case, Op. at 10 n.3, the 
First Circuit's view appears to be in accord with the commentary to 
s 3B1.1.  See U.S.S.G. s 3B1.1, comment., n.2.

     3  See United States v. Sobin, 56 F.3d 1423, 1428 (D.C. Cir. 
1995) ("The government's evidence of Sobin's elaborate scheme to 
defraud the bankruptcy court, involving multiple bank accounts, 

that the great majority of the circuits are correct, and that it 
is more faithful to the Sentencing Guidelines to consider the 
totality of the circumstances in determining whether an activ-
ity was "otherwise extensive," I respectfully dissent.

     Guideline s 3B1.1(a) directs the sentencing court to in-
crease a defendant's offense level by four if the defendant was 
an organizer or leader of a criminal activity "that involved 
five or more participants or was otherwise extensive."  (Em-
phasis added).  My colleagues hold that the second of these 
two alternative criteria is satisfied only by criminal activity 
that is the functional equivalent of the first, and they go on to 
define functional equivalence as a headcount of knowing and 
unknowing individuals.

     There is nothing in the language of s 3B1.1(a), however, 
that justifies limiting the term "otherwise extensive" to a 
headcount.  To the contrary, a commonsense reading sug-
gests several ways in which criminal activity may be adjudged 
"extensive."  The number of individuals involved is, to be 
sure, a sensible factor to consider.  But so are such other 
factors as duration, geographic reach, degree of organization-
al sophistication, and number of constituent transactions--as 
our sister circuits have found.4

__________
aliases and transactions, amply supports the implicit finding that 
Sobin orchestrated an 'extensive' criminal activity.");  United States 
v. Dale, 991 F.2d 819, 857 (D.C. Cir. 1993) (noting "the wide 
geographic reach of the criminal activity and the extensiveness of 
the actions taken to further the conspiracy").

     4  See, e.g., Yarnell, 129 F.3d at 1139 (relying on geographic 
scope, duration, number of victims, amount of losses, planning, 
complex execution, as well as number of persons involved);  Sand-
ers, 95 F.3d at 457 (relying on fact that activities "took place in 
several states");  United States v. Briscoe, 65 F.3d 576, 580, 590 (7th 
Cir. 1995) (holding that fraudulent loan operation, run by three 
criminal participants over four years and involving fifty-nine fraudu-
lent transactions totaling $120,000, constituted "otherwise exten-
sive" enterprise);  Mergerson, 4 F.3d at 347-48 (relying on "totality 
of the evidence," including amount, value, and purity of heroin 
negotiated, as well as number of participants);  Dale, 991 F.2d at 
857 (taking into account "the wide geographic reach of the criminal 

     This conclusion is only strengthened by consideration of the 
guideline's additional descriptor, the word "otherwise."  Had 
the Sentencing Commission used "similarly" extensive, rather 
than "otherwise" extensive, to describe s 3B1.1(a)'s second 
criterion, the court would have textual support for its head-
count limitation.  But the use of the word "otherwise" indi-
cates an intention to open the second category to factors 
different from those considered in the first, rather than to 
restrict it to those that are strictly of-a-piece.  See Webster's 
Third New International Dictionary 1598 (1976) (defining 
"otherwise" as "in a different way or manner" (emphasis 
added));  see also United States v. Alpers, 338 U.S. 680, 682-
84 (1950) (noting that, in statute making it an offense to 
kidnap "for ransom or reward or otherwise," term "or other-
wise" indicates that kidnaping is prohibited for any purpose 
and not simply for pecuniary gain, as would be suggested by 
the first two terms).

     Acknowledging that the text of s 3B1.1(a) does not confirm 
their interpretation, Op. at 11, my colleagues look instead in 
other directions.  First, they note the commentary to 
s 3B1.1, which states:  "In assessing whether an organization 
is 'otherwise extensive,' all persons involved during the course 
of the entire offense are to be considered.  Thus, a fraud that 
involved only three participants but used the unknowing 
services of many outsiders could be considered extensive."  
U.S.S.G. s 3B1.1, comment., n.3.  This commentary, however, 
merely instructs that all persons involved--and not simply 

__________
activity and the extensiveness of the actions taken to further the 
conspiracy");  Rodriguez, 981 F.2d at 1200 (relying on fact that drug 
operation "extended from Columbia to Florida to Boston to New 
York" and "included the purchase and street distribution of 100 
kilos of cocaine worth $350,000 in the wholesale market");  Dietz, 
950 F.2d at 54 (relying on "course of criminal activity that spanned 
twelve years, crossed into seven states, utilized many fictitious 
identities, infiltrated two distinct sets of [government] programs, 
and snared eight different governmental agencies in its intricately 
spun web," as well as number of persons involved);  United States v. 
McKenzie, 922 F.2d 1323, 1329 (7th Cir. 1991) (resting on number of 
couriers, cross-country trips, and transactions).

those who were knowing--should be considered.  It does not 
indicate that the number of persons is to be the only factor in 
assessing extensiveness.

     Moreover, other commentary to s 3B1.1 strongly suggests 
that the Commission did not intend sentencing courts to 
confine their analysis of "otherwise extensive" to the number 
of persons involved.  On the contrary, the commentary indi-
cates that in applying s 3B1.1, courts should consider wheth-
er the enterprise was extensive "in scope or in planning or 
preparation":

     In relatively small criminal enterprises that are not 
     otherwise to be considered as extensive in scope or in 
     planning or preparation, the distinction between organi-
     zation and leadership, and that of management or super-
     vision, is of less significance than in larger enterprises 
     that tend to have clearly delineated divisions of responsi-
     bility.  This is reflected in the inclusiveness of 
     s 3B1.1(c).
     
U.S.S.G. s 3B1.1, comment., background (emphasis added).5  
These are precisely the kind of factors considered by circuits 
__________
     5  Although the commentary set forth in the text explicitly 
mentions only s 3B1.1(c), its elaboration of the meaning of "other-
wise ... extensive" applies to s 3B1.1(a) and (b) as well.  Guideline 
s 3B1.1 states:

(a)  If the defendant was an organizer or leader of a criminal 
     activity that involved five or more participants or was 
     otherwise extensive, increase by 4 levels.

(b)  If the defendant was a manager or supervisor (but not an 
     organizer or leader) and the criminal activity involved five 
     or more participants or was otherwise extensive, increase 
     by 3 levels.

(c)  If the defendant was an organizer, leader, manager, or 
     supervisor in any criminal activity other than described in 
     (a) or (b), increase by 2 levels.
U.S.S.G. s 3B1.1.  As the guideline makes clear, the line between 
criminal activity covered by subsection (c), and that covered by 
subsections (a) and (b), is the activity's size (number of participants) 
or extensiveness.  The import of the commentary is its description 

that employ the totality of the circumstances test.  See supra 
note 4.

     My colleagues suggest two further reasons for limiting 
"otherwise extensive" to a headcount.  First, they worry that 
if "otherwise extensive" is not cabined by a headcount princi-
ple, courts will plunge into an "unconstrained inquiry."  Op. 
at 10.  This concern seems overstated.  Prior to the Sentenc-
ing Reform Act of 1984, a court's sentencing inquiry was 
indeed unconstrained.  See Mistretta v. United States, 488 
U.S. 361, 363-65 (1989).  Although it is true that the Sentenc-
ing Guidelines were intended to limit that discretion, they 
were not intended to squeeze out every last drop.  See Koon 
v. United States, 518 U.S. 81, 97, 112 (1996).  A court's 
analysis of whether criminal activity was "otherwise exten-
sive," based on factors that accord with a commonsense 
reading of the term and that have been applied by eight other 
circuits, is no more unconstrained than is the search for the 
meaning of many other dispositive, but equally vague, guide-
line terms.  See, e.g., U.S.S.G. s 2F1.1(b)(2)(B) ("more than 
minimal planning");  s 3B1.2(b) ("minor participant");  
s 3D1.2(b) ("common scheme or plan");  s 1B1.3 ("relevant 
conduct").  And, of course, a district court's determination 
remains ultimately constrained by appellate review for abuse 
of discretion.  See 18 U.S.C. s 3742(e).

     My colleagues also suggest that a headcount principle is 
required to prevent "double counting" of offense characteris-
tics taken into account elsewhere in the Guidelines, such as 
"more than minimal planning" or multiple victims.  See, e.g., 
s 2F1.1(b)(2).  But the "Commission 'plainly understands the 
concept of double counting, and expressly forbids it where it 

__________
of otherwise extensive as a function of "scope or ... planning or 
preparation."  My colleagues' interpretation of the commentary as 
indicating that scope, planning, and preparation are not factors to 
consider in determining whether criminal activity is otherwise ex-
tensive, but rather factors in determining the "entirely separate" 
question of degree of responsibility, Op. at 12, is inconsistent with 
the commentary's language.  See U.S.S.G. s 3B1.1, comment., back-
ground ("otherwise to be considered as extensive in scope or in 
planning or preparation" (emphasis added)).

is not intended.' " United States v. Valdez-Torres, 108 F.3d 
385, 389 (D.C. Cir. 1997) (quoting United States v. Williams, 
954 F.2d 204, 208 (4th Cir. 1992)).6  The Commission has not 
forbidden double counting here, nor even indicated that it is 
disfavored.  See s 1B1.1, comment., n.4 ("Absent an instruc-
tion to the contrary, the adjustments from different guideline 
sections are applied cumulatively....  For example, the ad-
justments from s 2F1.1(b)(2) (more than minimal planning) 
and s 3B1.1 (Aggravating Role) are applied cumulatively.").  
Nor is double counting truly at issue where, as in this case, 
the same conduct may be the ground for multiple adjust-
ments based on different attributes of culpability.  See, e.g., 
United States v. Kelly, 993 F.2d 702, 704-05 (9th Cir. 1993) 
(holding that enhancements for both more than minimal 
planning under s 2F1.1(b)(2), and leading an extensive crimi-
nal activity under s 3B1.1(a), may be applied without double 
counting because the two derive from distinct sentencing 
concerns).7

__________
     6  See id., 108 F.3d at 389 n.9 (noting, for example, that applica-
tion note 1 to U.S.S.G. s 2A2.4 expressly directs against enhance-
ment for an "official victim" under s 3A1.2 when the offense itself is 
assault on a government officer);  United States v. Lilly, 13 F.3d 15, 
19-20 (1st Cir. 1994) ("Double counting in the sentencing context is 
a phenomenon that is less sinister than the name implies.  Since 
double counting is often perfectly proper, the guidelines themselves 
are the most helpful aid in the task of separating permissible double 
counting from its impermissible counterpart....  We believe the 
Commission's ready resort to explicitly stated prohibitions against 
double counting signals that courts should go quite slowly in 
implying further such prohibitions where none are written." (inter-
nal quotations omitted));  see also United States v. Johnstone, 107 
F.3d 200, 212-13 (3d Cir. 1997);  United States v. Wong, 3 F.3d 667, 
670-71 (3d Cir. 1993).

     7  See United States v. Cobleigh, 75 F.3d 242, 251 (6th Cir. 1996) 
(applying both more than minimal planning enhancement and en-
hancement under s 3B1.1(b));  United States v. Curtis, 934 F.2d 
553, 556-57 (4th Cir. 1991) (applying both more than minimal 
planning enhancement and enhancement under s 3B1.1(c));  see 

     Finally, even if double counting were of critical concern 
with respect to s 3B1.1(a), it would not counsel excluding all 
factors except for the number of persons involved.  There are 
many other factors upon which extensiveness could properly 
be based, such as duration and geographic scope, that are not 
taken into consideration by any guideline other than 
s 3B1.1(a).  Such factors pose no risk of double counting 
under any theory, and there is thus no basis for excluding 
them from consideration at sentencing.8

                          --------------

     The court does not dispute that if "otherwise extensive" 
were defined by the totality of the circumstances, rather than 
by a headcount, the four-level enhancement of s 3B1.1(a) 
would be warranted in this case.  Because I conclude that the 
broader definition is more faithful to the Sentencing Guide-
lines, I would affirm the defendant's sentence in all respects.

__________

also United States v. Syrax, 235 F.3d 422, 428 (9th Cir. 2000);  
United States v. Then, 56 F.3d 464, 466 (2d Cir. 1995).

     8  It is not an answer to say that such factors may still be 
considered in granting an upward departure from the range estab-
lished by the applicable guidelines.  Op. at 13-14.  The availability 
of departures, which are intended to address circumstances "not 
adequately taken into consideration by the Sentencing Commis-
sion," 18 U.S.C. s 3553(b) (emphasis added), cannot logically be 
used to reach a conclusion about which circumstances the Commis-
sion did take into consideration.  Moreover, the threshold for 
determining whether a departure from the Guidelines is warrant-
ed--i.e., conduct outside the heartland of cases governed by an 
offense guideline, see U.S.S.G. ch.1, pt.A(4)(b)--is significantly dif-
ferent from the standard for applying an enhancement within the 
Guidelines.