What is the test for determining whether a defendant was an "organizer, leader, manager or supervisor" of a crime?

MultiRegion, United States of America

The following excerpt is from U.S. v. Garcia, 36 F.3d 1103 (9th Cir. 1994):

We review for clear error a district court's determination that a defendant was an "organizer, leader, manager or supervisor" of an offense. United States v. Roberts, 5 F.3d 365, 371 (9th Cir.1993). We review for an abuse of discretion a district court's determination that information is reliable enough to support a sentencing adjustment. United States v. Petty, 982 F.2d 1365, 1369 (9th Cir.1993), amended 992 F.2d 1015 (9th Cir.1993), cert. denied 114 S.Ct. 684 (1994).

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