Thursday, June 11, 2009

Gang Affiliation Evidence Supported Denial of Minor Role Reduction

US v. Vo, No. 08-8062 (10th Cir. June 10, 2009) (unpublished): district court did not err in denying a reduction for minor role participant where there was evidence Mr. Vo was an active member of a gang known to traffic in narcotics and where all but one of the co-defendants was also associated with the gang.