143636P.pdf   03/15/2016  United States  v.  Brenda Laws
   U.S. Court of Appeals Case No:  14-3636
                          and No:  14-3639
                          and No:  14-3640
                          and No:  14-3642
   U.S. District Court for the Eastern District of Arkansas - Little Rock   
   [PUBLISHED] [Kelly, Author, with Murphy and Benton, Circuit Judges] 
   Criminal cases - Criminal law and sentencing. The district court did not 
   err in imposing an enhancement under Guidelines Sec. 2B1.1(b)(10)(C) for 
   sophisticated means in determining defendant Brenda Laws' sentence; the 
   court did err in imposing an enhancement under Guidelines Sec. 3B1.1(a) 
   for role in the offense as there was insufficient evidence to show 
   defendant Brenda Laws was an organizer or a leader; no error in imposing 
   an enhancement in defendant Brenda Laws' sentence under Guidelines Sec. 
   2B1.1(b)(2)(B) (2013) for an offense involving 50 or more victims; the 
   district court did not abuse its discretion by granting the government's 
   motion to reconsider a suppression order with respect to defendant Marvin 
   Laws' statement to an IRS agent as the government provided sufficient 
   justification for its failure to present all relevant evidence at the 
   first hearing on Laws' belated motion to suppress; with respect to the 
   merits of the motion, the court did not err in finding the statement was 
   admissible because Laws was not in custody at the time he made the 
   statement and he had been advised that he could end the encounter; the 
   evidence was sufficient to support defendant Lareka Laws' and defendant 
   Jameel Laws' convictions for tax fraud and making a false claim to the 
   IRS.