Clarifying Managerial Role Enhancements and Mandatory Supervised-Release Revocation in Sentencing: United States v. Anderson

Introduction

United States v. Brandon Anderson, decided by the Eleventh Circuit on March 31, 2025, addresses two fundamental sentencing questions under federal law: (1) the proper application of the three-level Sentencing Guidelines enhancement for a managerial or supervisory role under U.S.S.G. § 3B1.1(b), and (2) the procedural and substantive considerations governing a consecutive sentence upon revocation of supervised release under 18 U.S.C. §§ 3553(a), 3583(e) & (g) and U.S.S.G. § 7B1.4.

In this appeal, Brandon Anderson challenged his total 240-month sentence—216 months on drug and firearm counts and a consecutive 24 months for violating supervised release. The principal issues were: Did the district court err in imposing a three-level aggravating role enhancement? Was the consecutive supervised-release revocation sentence procedurally or substantively unreasonable?

Summary of the Judgment

The Eleventh Circuit unanimously affirmed. First, it held that Anderson clearly qualified for the § 3B1.1(b) enhancement because he managed or supervised at least one other participant in a drug‐trafficking conspiracy, supported by recorded calls and distribution networks. Second, Anderson’s 24-month consecutive supervised-release revocation term was procedurally unobjectionable—it fell within the advisory Guidelines range (24–30 months) and statutory maximum for a Class C felony mandatory revocation under 18 U.S.C. § 3583(g). Finally, his 216-month substantive sentence for Counts 1–3, though a downward variance from the 262–327 month Guidelines range, was reasonable given the district court’s balanced consideration of the § 3553(a) factors.

Analysis

1. Precedents Cited

• Standard of Review:
  • De novo review for legal Sentencing Guidelines issues (United States v. Rothenberg, 610 F.3d 621 (11th Cir. 2010)).
  • Clear-error review for factual findings and aggravating-role enhancements (United States v. Shabazz, 887 F.3d 1204 (11th Cir. 2018); United States v. Clarke, 562 F.3d 1158 (11th Cir. 2009)).
  • Abuse-of-discretion review for overall reasonableness (United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc); Gall v. United States, 552 U.S. 38 (2007)).
• Managerial/Supervisory Role Enhancement:
  • Requirement of managing at least one participant—mere asset control is insufficient (United States v. Sosa, 777 F.3d 1279 (11th Cir. 2015); United States v. Jennings, 599 F.3d 1241 (11th Cir. 2010)).
  • Demonstrated by arranging transactions, recruiting or supervising co-conspirators (United States v. Matthews, 168 F.3d 1234 (11th Cir. 1999); United States v. LaFraugh, 893 F.2d 314 (11th Cir. 1990)).
• Supervised Release Revocation:
  • Mandatory revocation upon drug possession violation—no need to consider § 3553(a) factors (18 U.S.C. § 3583(g)(1); United States v. Brown, 224 F.3d 1237 (11th Cir. 2000)).
  • Guideline range for revocation determined by original offense class and policy statement § 7B1.4(a).
  • Plain error review if defendant failed to object below (United States v. Vandergrift, 754 F.3d 1303 (11th Cir. 2014)).
• Reasonableness and Disparity Considerations:
  • The district court’s sentence must be “sufficient, but not greater than necessary” under 18 U.S.C. § 3553(a) (Butler, 39 F.4th 1349 (11th Cir. 2022)).
  • Proper consideration of criminal history, seriousness, deterrence, and unwarranted disparities among similarly situated defendants (United States v. Docampo, 573 F.3d 1091 (11th Cir. 2009); United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015)).

2. Legal Reasoning

Managerial/Supervisory Role: Applying U.S.S.G. § 3B1.1(b), the court confirmed two requirements: (1) the defendant must have managed or supervised at least one other participant, and (2) the criminal activity must involve five or more participants or be otherwise extensive. Anderson’s coordination of drug fronts, instructions on fentanyl “cuts,” and recorded calls with multiple distributors satisfied both prongs. The court rejected Anderson’s argument that asset control alone could trigger the enhancement, reaffirming Sosa.

Supervised-Release Revocation: Under 18 U.S.C. § 3583(g), possession of a controlled substance during supervision mandates revocation. Although § 3553(a) factors generally guide sentencing, mandatory revocation requires no additional § 3553(a) analysis to impose a term—only when fashioning the term’s length may the court consult guidelines and policy statements. Anderson’s 24 months fell at the bottom of the advisory 24–30 month range under U.S.S.G. § 7B1.4(a), and did not exceed the statutory maximum for a Class C felony.

Substantive Reasonableness: For Counts 1–3, the district court varied downward from the 262–327 month advisory range to 216 months. In doing so, it weighed Anderson’s lengthy criminal history, the severity of fentanyl trafficking, and deterrence heavily but did not ignore mitigating evidence. This balancing fell “within the ballpark of permissible outcomes” (Gall) and avoided unwarranted disparities by aligning with similarly situated defendants.

3. Impact

United States v. Anderson cements two key sentencing principles:

• Managerial Enhancement Clarified: District courts must find actual supervisory control over at least one participant before applying U.S.S.G. § 3B1.1(b). Mere financial or asset control is insufficient.
• Mandatory Revocations: Sentences imposed under 18 U.S.C. § 3583(g) require no independent § 3553(a) justification for revocation; the court’s role is limited to setting a term within the guidelines and statutory limit.

Lower courts will rely on Anderson to reinforce clear-error review of role enhancements and plain-error scrutiny of supervised release mistakes. The decision also underscores that substantial variances remain presumptively reasonable when properly tied to § 3553(a) factors and guideline range calculations.

Complex Concepts Simplified

1. § 3B1.1(b) “Managerial Role” Enhancement: A three-level increase to the offense level when a defendant supervises or manages at least one other person in a criminal conspiracy. You cannot get it by simply owning or handling the conspiracy’s assets.

2. Mandatory vs. Discretionary Revocation: If a person on supervised release uses drugs, the court must revoke release (mandatory). It then may set a prison term up to the maximum allowed for the original offense. The judge need not recite the usual sentencing factors.

3. Plain Error Review: When a defendant fails to object at sentencing, appellate courts will correct only obvious legal mistakes that affect fairness or public confidence. Subtle errors are forfeited.

4. “Ballpark” Doctrine: An appellate court will uphold any sentence within or near the properly calculated Guidelines range unless the district court abused its wide discretion.

Conclusion

United States v. Anderson provides important guardrails for federal sentencing courts: it confirms that an aggravating-role enhancement under § 3B1.1(b) requires actual management of participants, and it affirms the narrow role of § 3553(a) analysis in mandatory supervised-release revocations. By applying clear-error and plain-error review standards, the Eleventh Circuit has reinforced the deference owed to district courts’ fact-finding and sentencing discretion, while preserving uniformity and fairness in federal sentencing practice.