Second Circuit -- United States v. Roberts

Deft's proffer statements were not unduly economically coerced.  

District Court applied the correct standard, only focusing on the potential loss of work because it was the harm that deft had claimed.

Proffer statements appropriately admitted, as the R.410 waiver was good, and the statements were used to rebut deft's claims.

No error in imposing the 'position of responsibility' sentencing bump.

Remand to clarify why trial court sentenced according to retail as opposed to wholesale value of the cocaine.


United States v. Roberts