United States v. Berry

I join the Panel’s opinion in full. I write separately to offer additional thoughts regarding the special-skill enhancement, U.S.S.G. § 3B1.3, and Mr. Berry’s contention that his truck-driving skills do not qualify as a special skill. These additional comments are fully in accord with the Panel’s opinion, as I read it, and are meant to *836further clarify the application of this Guideline.

Beginning with the Guideline’s language, it states that “[i]f the defendant ... used a special skill[ ] in a manner that significantly facilitated the commission or concealment of the offense, increase by 2…