Does a defendant need to be identified as an "organizer, leader, manager or supervisor"?

MultiRegion, United States of America

The following excerpt is from U.S. v. Gutierrez-Aguilar, 995 F.2d 233 (9th Cir. 1993):

We review for clear error whether a defendant was "an organizer, leader, manager or supervisor." United States v. Hoac, No. 91-50193, slip op. 2809, 2831 (9th Cir. March 26, 1993).

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