The following excerpt is from United States v. Harris, 999 F.3d 1233 (9th Cir. 2021):
Although a defendant cannot receive a leadership enhancement merely by playing an important role in an offense or by suggesting that the offense be committed, Defendant qualifies for the two-level enhancement if he was an "organizer." 3B1.1(c). "A defendant organizes other participants if he has the necessary influence and ability to coordinate the[ir] behavior ... so as to achieve the desired criminal result[s]. " United States v. Holden , 908 F.3d 395, 402 (9th Cir. 2018) (alterations in original) (quoting United States v. Doe , 778 F.3d 814, 826 (9th Cir. 2015) ). A defendant can "organize" a single codefendant. Id.
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