United States v. Blackbird, 949 F.3d 530, 532 (10th Cir. 2020)
USSG § 2A3.2(b)(1) – 4 level enhancement for Sex Abuse of minor in custody or care or supervisory control of defendant
The Tenth interprets this enhancement as requiring the defendant must have a degree of authority or control over minor. Mere proximity or familial relationship not enough; age of minor also a consideration