Logistics Control Equals Managerial Role: Sixth Circuit Affirms §3B1.1(c) Enhancement Based on Directing a Co-Participant Without Proof of Profit Share or Direct Communications

Introduction

In United States v. Bryan Darnel Ragsdale (6th Cir. Oct. 29, 2025), a non-precedential opinion authored by Judge Readler and joined by Judges Murphy and Bloomekatz, the Sixth Circuit affirmed a 170-month sentence imposed on a defendant who pleaded guilty to conspiracy and distribution of methamphetamine and fentanyl. The case centers on two principal issues: (1) whether the district court procedurally erred by applying a two-level role enhancement under § 3B1.1(c) of the U.S. Sentencing Guidelines based on the defendant’s managerial role in the conspiracy; and (2) whether the mid-Guidelines sentence was substantively unreasonable in light of the defendant’s troubled upbringing.

The court held there was no reversible error. It concluded that directing a co-participant (here, a co-defendant who made deliveries) and controlling the details of the drug transactions constituted a managerial role warranting the two-level enhancement, even absent evidence of profit allocation or direct communications between the conspirators. The court also affirmed the within-Guidelines sentence as substantively reasonable, rejecting the claim that the district court insufficiently weighed the defendant’s personal circumstances.

Summary of the Opinion

The Sixth Circuit affirmed the district court on both procedural and substantive reasonableness. On the procedural point, it upheld a § 3B1.1(c) enhancement where the defendant:

Negotiated the drug deals directly with a confidential informant;
Chose the time, location, and quantity for multiple controlled buys;
Dispatched his co-defendant to deliver drugs, including when he was out of town and when completing a split delivery (partial by him, remainder by her); and
Stood watch during a delivery she conducted.

On substantive reasonableness, the court affirmed a mid-Guidelines sentence (170 months within a 151–188 month range), recognizing the district court’s thorough consideration of § 3553(a) factors, including the defendant’s history of homelessness from age 16, his extensive record, and deterrence needs. The court declined to reweigh the factors on appeal and emphasized the presumption of reasonableness for within-Guidelines sentences.

Analysis

Precedents Cited and Their Influence

Gall v. United States, 552 U.S. 38 (2007) and United States v. Rayyan, 885 F.3d 436 (6th Cir. 2018): The court applied Gall’s procedural/substantive reasonableness framework (proper Guidelines calculation, advisory treatment, consideration of § 3553(a), no impermissible factors, non-clearly-erroneous facts, adequate explanation), as reflected in Rayyan’s Sixth Circuit articulation. These cases set the lens for appellate review.
United States v. Bolds, 511 F.3d 568 (6th Cir. 2007): Reiterated the mixed standard of review: deference to factual findings (clear-error review) and fresh review on legal conclusions, within the overall abuse-of-discretion framework.
United States v. Washington, 715 F.3d 975 (6th Cir. 2013) (deference to trial judge) and United States v. Wombles, 673 F. App’x 489 (6th Cir. 2016): The Sixth Circuit emphasized deference to district courts on role determinations because trial judges are best positioned to assess whether someone functioned as a leader/manager in a conspiracy. Wombles also supports that directing a courier can suffice for § 3B1.1(c), even on a one-time or temporary basis.
United States v. Gort-Didonato, 109 F.3d 318 (6th Cir. 1997) and Guidelines Commentary (USSG § 3B1.1 cmt. n.2 (2024)): The operative test is whether the defendant exerted control over at least one participant in a supervisory, managerial, leadership, or organizational capacity. This frames the enhancement’s threshold.
United States v. Hills, 27 F.4th 1155 (6th Cir. 2022): Defines “participant” as someone criminally responsible even if not convicted (USSG § 3B1.1 cmt. n.1). This ensures the co-defendant’s deliveries qualify in the analysis.
United States v. Washington, 127 F.3d 510 (6th Cir. 1997); United States v. Vasquez, 560 F.3d 461 (6th Cir. 2009) (citing United States v. Lalonde, 509 F.3d 750 (6th Cir. 2007)); United States v. Plunk, 415 F. App’x 650 (6th Cir. 2011): These cases closely mirror Ragsdale’s facts—negotiating sales and directing others (e.g., a girlfriend, a brother, or a recruited associate) to deliver drugs. Each supports applying the role enhancement where the defendant exercises control over an accomplice in executing transactions.
United States v. Castilla-Lugo, 699 F.3d 454 (6th Cir. 2012): The government need not prove profit share, recruitment, or other profit-control factors to justify the role enhancement. This undercuts defense arguments that the absence of such proof defeats § 3B1.1(c).
United States v. Johnson, 934 F.3d 498 (6th Cir. 2019): District courts may rely on reasonable inferences from the record when explaining sentences. This legitimizes the district court’s inference that Ragsdale directed Craig’s deliveries without direct intra-conspiracy communications in the record.
United States v. Christian, 804 F.3d 819 (6th Cir. 2015): Clarifies that management of property alone is insufficient for § 3B1.1. The Sixth Circuit distinguished Christian because Ragsdale managed a participant, not just property.
United States v. Collins, 877 F.3d 362 (7th Cir. 2017) (Seventh Circuit): Collins suggested a narrower approach—no enhancement for a single direction to a courier as an equal rather than subordinate. The Sixth Circuit acknowledged Collins but adhered to its own line (e.g., Wombles and Plunk) permitting an enhancement even for one-time or temporary direction of a courier.
United States v. Young, 847 F.3d 328 (6th Cir. 2017) and United States v. Vowell, 516 F.3d 503 (6th Cir. 2008): Articulate the substantive reasonableness standard: sentences must be proportionate to the offense and offender and sufficient but not greater than necessary under § 3553(a).
United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (en banc): Confirms the presumption of reasonableness for within-Guidelines sentences.
United States v. Frei, 995 F.3d 561 (6th Cir. 2021): Appellate courts generally will not reweigh § 3553(a) factors or second-guess a district court’s chosen balance when the court’s explanation shows reasoned consideration.

The Court’s Legal Reasoning

The Sixth Circuit applied a deferential abuse-of-discretion review for procedural reasonableness, treating the district court’s factual findings with clear-error deference and its legal conclusions with fresh review. Against that backdrop, the panel articulated the operative § 3B1.1(c) test: whether the defendant exerted control over at least one participant in a supervisory, managerial, leadership, or organizational capacity.

The court concluded that Ragsdale’s conduct satisfied the test:

He negotiated all transaction details directly with the confidential informant (quantity, timing, and location).
He orchestrated deliveries by his co-defendant, Craig, including dispatching her when he was out of town and coordinating a two-stage delivery (partial by him; remainder by her).
He stood watch while Craig delivered drugs at a location he selected.
Craig’s own communications with the informant were limited to a single instance outside the drop, underscoring Ragsdale’s central coordinating role.

Importantly, the court rejected defense arguments that the government must prove additional indicia of leadership—such as recruiting the accomplice, exercising decision-making authority over major aspects beyond logistics, or taking a larger share of proceeds. Relying on Castilla-Lugo and similar cases, the court expressly held that proof of profit allocation, source control, or direct inter-conspirator communications is not required to support a § 3B1.1(c) enhancement when the record supports a reasonable inference of supervisory or managerial control over a participant.

The panel distinguished cases limiting § 3B1.1 to people-management rather than property-management (Christian), noting that Ragsdale’s direction of Craig—an unquestionably criminally responsible participant—squarely satisfied the “management of people” criterion. And while acknowledging the Seventh Circuit’s narrower reading in Collins, the panel followed the Sixth Circuit’s own approach (Wombles, Plunk), which permits the enhancement even when the direction of a courier is one-time or temporary. Here, the facts were stronger still: Ragsdale exercised control repeatedly across three transactions.

On substantive reasonableness, the court applied the presumption of reasonableness to the within-Guidelines sentence and declined to reweigh the § 3553(a) factors. The sentencing judge carefully considered the defendant’s difficult upbringing and homelessness as a teenager, his extensive criminal history, and the need for both specific and general deterrence, as well as rehabilitation. The appellate court found no basis to disturb the district court’s mid-range selection, and emphasized that the district court was not required to further explain why it chose the middle rather than the low end of the range.

Impact and Forward-Looking Implications

Although not recommended for publication (and thus not binding precedent), the opinion fortifies several practical propositions in Sixth Circuit sentencing:

Logistics control suffices: Setting the terms of the deal (quantity, time, location) and dispatching a co-participant for delivery can establish a “manager” or “supervisor” role under § 3B1.1(c).
People vs. property: The key distinction remains whether the defendant managed people, not merely property. Directing a co-conspirator is enough; controlling storage alone is not.
No profit-share proof required: The absence of evidence about who sourced the drugs, who controlled inventory, or who took a larger share of proceeds does not preclude the enhancement if the record supports managerial control over a participant.
Reasonable inferences are permissible: District courts may infer direction and control from the structure and execution of transactions without direct communications evidence between co-conspirators.
One-time direction can suffice: The Sixth Circuit continues to recognize that even a one-time or temporary direction of a courier may warrant § 3B1.1(c), a point on which other circuits (e.g., the Seventh Circuit in Collins) are more cautious. This divergence can influence litigation strategies and, potentially, future inter-circuit dialogue.
Appellate deference is substantial: Role assessments are fact-intensive; district courts’ on-the-ground evaluations receive deferential review. Within-Guidelines sentences retain a strong presumption of reasonableness on appeal.

For practitioners, the opinion underscores that the government can successfully support a role enhancement through circumstantial evidence of coordination and direction, even if it lacks records of internal communications or profit allocation. Conversely, defense counsel seeking to avoid a § 3B1.1(c) enhancement should build a record emphasizing mutual, coequal participation, absence of direction, and independent decision-making by the purported “courier,” while challenging inferences of hierarchy where the facts support an equal partnership.

Complex Concepts Simplified

§ 3B1.1(c) Role Enhancement: Adds two offense levels if a defendant acted as an organizer, leader, manager, or supervisor. The enhancement targets those who control or direct at least one other criminally responsible participant.
Participant: Someone criminally responsible for the offense, even if not convicted. A co-defendant making deliveries qualifies.
Managing People vs. Managing Property: The enhancement requires management of people. Being in charge of storage facilities, money, or stash houses—alone—doesn’t suffice. Directing another person’s criminal actions does.
Procedural vs. Substantive Reasonableness: Procedural concerns address how the sentence was reached (correct Guidelines, considered factors, explained decision). Substantive reasonableness asks whether the sentence length is fair and appropriate given the offense and offender, and not greater than necessary.
Standard of Review: Appellate courts defer to district courts on factual findings (clear-error review) and require an abuse of discretion to reverse. Role determinations are highly fact-dependent, so deference is substantial.
Presumption of Reasonableness: A sentence within the correctly calculated Guidelines range is presumed reasonable on appeal. Overcoming this presumption is difficult; appellate courts generally don’t reweigh the § 3553(a) factors.
Reasonable Inferences: Judges can draw logical conclusions from the record (e.g., a defendant who negotiates all details and dispatches an accomplice likely exercises managerial control), even without direct proof of internal communications.

Conclusion

United States v. Ragsdale reinforces the Sixth Circuit’s pragmatic approach to § 3B1.1(c). The opinion confirms that “managerial” or “supervisory” status can be shown through evidence of logistical control over transactions and direction of a co-participant’s actions, without additional proof of profit distribution or direct communications. It also reiterates the distinction between managing people and managing property and emphasizes the appellate deference given to district courts’ role findings and to within-Guidelines sentences.

While non-precedential, the decision aligns with and strengthens existing Sixth Circuit authority on role enhancements in drug conspiracies. It provides a clear roadmap for prosecutors seeking to justify § 3B1.1(c) enhancements through circumstantial evidence of coordination and direction, and it signals to defense counsel the importance of developing a record that negates hierarchical control, especially in courier scenarios. On sentencing review more broadly, the case underscores the continued vitality of the presumption of reasonableness for within-Guidelines sentences and the limited role of appellate courts in rebalancing § 3553(a) factors once the district court has provided a reasoned explanation.