United States of America v. Jose Farias

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 24-2725
U NITED STATES OF A MERICA,
Plaintiff-Appellee,
v.
JOSE F ARIAS,
Defendant-Appellant.
____________________
Appeal from the United States District Court for the
Northern District of Illinois, Eastern Division.
No. 17-cr-530 — John Robert Blakey, Judge.
____________________
A RGUED M AY 22, 2025 — DECIDED A UGUST 7, 2025
____________________
Before EASTERBROOK, S T. EVE, and K IRSCH , Circuit Judges.
ST. EVE, Circuit Judge. Jose Farias was a high-volume drug
trafficker. Together with a network of co-conspirators, he
brought millions of doses of heroin and cocaine to the Chi-
cagoland area in 2015 and 2016. Then, the Drug Enforcement
Administration (“DEA”) caught up to him.
A grand jury indicted Farias for conspiracy to distribute
heroin and cocaine and possession of cocaine with the intent

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2 No. 24-2725
to distribute. He went to trial on the charges and was con-
victed. At his sentencing, the district court attributed 130 kil-
ograms of heroin and 45 kilograms of cocaine to his trafficking
activities and imposed a 25-year term of imprisonment.
Farias appeals, asserting that trial testimony identifying
his voice on recorded calls violated his constitutional rights,
the district court erroneously instructed the jury that it could
give independent weight to translated transcripts of the calls,
there was insufficient evidence to support his conviction, and
the district court miscalculated his Guidelines range at sen-
tencing. We affirm.
I. Background
In July of 2015, Jose Farias began trafficking large quanti-
ties of heroin and cocaine to the Chicagoland area. The plan
was simple. Farias would pay a Texas truck dispatcher cash
to send seemingly empty tractor-trailers to Chicago. In reality,
the drug conspiracy would load ten to twenty kilograms of
heroin or cocaine in hidden compartments (“traps”) in the
trucks’ axles. When the shipments arrived, co-conspirators re-
cruited and trained by Farias would disassemble the traps
and deliver the drugs to a customer Farias designated. They
then would reload the traps with cash proceeds and send the
trucks back to Texas.
There was just one catch. The Texas truck dispatcher
tipped off the FBI shortly after Farias contacted him. So fed-
eral agents were on to the conspiracy from its inception. In
early 2016, the DEA and local law enforcement set up remote
surveillance of a warehouse in Sugar Grove, Illinois. They ob-
served the conspiracy unloading drugs from a tractor-trailer,
intervened, and intercepted nearly 21 kilograms of heroin.

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No. 24-2725 3
The drug conspiracy continued despite the seizure, and
the government’s investigation followed. After Farias moved
the operation to a lot on Harrison Street in West Chicago, the
DEA again set up surveillance. And in April of 2016, agents
seized another 21 kilograms of heroin. During this seizure,
law enforcement also arrested a key co-conspirator, Jesus
Martinez-Reyes, who agreed to cooperate with the investiga-
tion. Then, in November of 2016, the DEA tracked the con-
spiracy to a final location, a mechanic shop in Channahon, Il-
linois. There, it intercepted nearly 17 kilograms of cocaine. It
also arrested the owner of the shop, Raul Muñoz, and another
co-conspirator, Eduardo Yanez-Barrera. Both agreed to coop-
erate and lead investigators to their off-site boss: Farias.
In the weeks that followed his arrest, Yanez-Barrera made
recorded calls with Farias to discuss upcoming drug ship-
ments and their prices. During one call, Farias admonished
Yanez-Barrera in Spanish, warning him to be more careful:
Mr. Farias: I need you to listen to me, dude, because if
something happens, dude, and it’s because of some-
thing dumb you did, there won’t, there won’t be any
way to help you … Don’t do things like that. Do things
correctly because of the current problem.
Mr. Yanez-Barrera: Okay.
Mr. Farias: We’re going to change everything. Every-
thing is going to change [unintelligible] no longer go-
ing to work there with [unintelligible], but we need
you guys to take the money out so it can be delivered.
In another call, Farias instructed Yanez-Barrera on how to di-
vide proceeds between the conspirators.

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4 No. 24-2725
A grand jury subsequently returned a two-count indict-
ment charging Farias with conspiracy to distribute heroin and
cocaine, and possession of cocaine with intent to distribute it,
in violation of 21 U.S.C. §§ 841(a)(1), 846.
Farias pleaded not guilty and proceeded to trial on the
charges. In the government’s case in chief, four cooperating
witnesses testified: Martinez-Reyes, Muñoz, and two Texas
truck dispatchers. Their testimony revealed the far-reaching
scope of the drug trafficking operation.
Martinez-Reyes related how Farias had taught him to dis-
assemble tractor-trailers and access their traps at a warehouse
in Naperville. He further testified that after this crash course
in drug trafficking and truck mechanics, he unloaded four
shipments from Farias at that same warehouse, each contain-
ing between ten and twenty kilograms of heroin. Martinez-
Reyes also told the jury that he unloaded an additional three
or four unseized shipments of heroin from Farias at the Sugar
Grove Warehouse and the Harrison Street Lot. Muñoz, for his
part, testified to unloading two unseized shipments of be-
tween 15 and 16 kilograms of cocaine at the Channahon me-
chanic shop.
The Texas truck dispatchers corroborated Martinez-
Reyes’s and Muñoz’s accounts. One dispatcher testified to co-
ordinating approximately five or six deliveries to Chicago at
Farias’s behest. Another testified to dispatching between 15
and 20 trucks for Farias to destinations in Chicago, Northern
Indiana, and Atlanta.
The jury also heard recordings of Yanez-Barrera’s phone
calls with Farias in Spanish and saw transcripts with English
language translations of the calls. To lay the foundation for

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No. 24-2725 5
this evidence, DEA Agents Betancourth and Alarcon identi-
fied Farias’s voice on the recordings. Agent Betancourth re-
lied solely on a stipulated voice exemplar to identify Farias’s
voice, while Alarcon relied both on the exemplar and hearing
Farias speak in the courtroom during trial.
The jury convicted Farias on both counts.
Farias moved for a judgment of acquittal, or, alternatively,
a new trial. He contended that there was insufficient evidence
to support his conviction, that Agent Alarcon’s voice identifi-
cation violated his constitutional rights, and that the court im-
properly instructed the jury on the evidentiary weight of the
translated transcripts. The district court denied his motions.
At sentencing, the court found by a preponderance of the
evidence that 130 kilograms of heroin and 45 kilograms of co-
caine were attributable to Farias’s trafficking activities. It also
concluded that Farias was a “leader” or “organizer” of the
conspiracy and applied an aggravating role sentencing en-
hancement. The court then calculated Farias’s Guidelines
range to be 360 months to life and ultimately sentenced him
to a below Guidelines sentence of 300 months in prison.
Farias appeals both his conviction and his sentence.
II. Discussion
Our decision proceeds in four parts. We first consider Far-
ias’s challenges to the admission of Agent Alarcon’s voice
identification and to the court’s jury instructions. After assur-
ing ourselves of the fairness of Farias’s trial, we then review
the sufficiency of the evidence supporting his conviction and
the district court’s calculation of his Guidelines range.

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6 No. 24-2725
A. Voice Identification
We begin with Farias’s assertion that admission of Agent
Alarcon’s voice identification violated his constitutional
rights. We review the district court’s legal conclusions de
novo and its underlying factual findings for clear error. See
United States v. Haldorson, 941 F.3d 284, 290 (7th Cir. 2019);
United States v. Bonin, 932 F.3d 523, 543 (7th Cir. 2019).
When laying the foundation for his identification of Farias,
Alarcon testified that he compared the voice on the recorded
calls to a stipulated exemplar of Farias’s voice. Then, the gov-
ernment asked Alarcon:
Q. During the course of this trial, did you ever have
occasion to overhear the defendant speaking?
A. Yes.
Q. When?
A. I believe it was on Thursday of last week.
Q. And what language was he speaking?
DEFENSE COUNSEL: Objection.
THE COURT: Sustained.
The court held a sidebar where the defense argued that reli-
ance on in-court proceedings to identify Farias’s voice was
“prejudicial” and “interfere[d] with his right to be able to de-
fend himself.” The court overruled the objection, explaining
that it had initially sustained the objection only out of concern
that the questioning would go “into the content of some con-
versation he had in court, which would obviously be between
himself and an attorney.”

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No. 24-2725 7
With the government warned not to inquire into the con-
tents of attorney-client privileged conversations, the voice
identification proceeded:
Q. Agent Alarcon, you were just testifying about over-
hearing certain conversations involving defendant.
What was the volume of his voice?
A. Very loud.
Q. Okay. And did it sound like the same person from
the voice exemplar that you reviewed?
DEFENSE COUNSEL: Objection.
ALARCON: Yes.
THE COURT: Overruled.
The defense did not ask Alarcon about the nature of the over-
heard conversation on cross-examination, nor did he seek
leave to examine Alarcon outside of the presence of the jury.
After the jury returned a guilty verdict, Farias moved for
a new trial, citing, in part, Alarcon’s reliance on hearing him
speak at trial to identify his voice. The district court heard ar-
gument on the question twice before finding that the state-
ments Alarcon overheard were not private communications
between Farias and his attorney, so admitting Alarcon’s testi-
mony was not error.
On appeal, Farias renews his contention that admission of
Alarcon’s voice identification testimony violated his rights—
specifically his Fifth Amendment right against self-incrimina-
tion and his Sixth Amendment right to counsel. We see no
merit in either theory.

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8 No. 24-2725
The Fifth Amendment provides that “no person … shall
be compelled in any criminal case to be a witness against him-
self.” U.S. Const. amend. V. The Amendment thus protects de-
fendants against only a narrow class of self-incriminating con-
duct: compelled testimony. See United States v. Hubbell, 530
U.S. 27, 34 (2000) (“The word ‘witness’ in the constitutional
text limits the relevant category of compelled incriminating
communications to those that are ‘testimonial’ in character.”).
“[I]dentifiable physical characteristics” are nontestimonial
evidence that falls outside the privilege against self-incrimi-
nation. United States v. Dionisio, 410 U.S. 1, 5–6 (1973). So as
Farias conceded at oral argument, he does not have a Fifth
Amendment privacy interest in the sound of his voice, see
United States v. Neighbors, 590 F.3d 485, 493 (7th Cir. 2009), and
Alarcon’s reliance on hearing the characteristics of his voice
at trial did not violate his Fifth Amendment rights.
In the alternative, Farias asserts that admission of Alar-
con’s testimony interfered with his right to counsel and trans-
gressed our precedent in United States v. Jones, 600 F.3d 847,
859–60 (7th Cir. 2010).
In Jones, we held that a trial court erred when it admitted
voice identification testimony based on overhearing the de-
fendant speak privately with his attorney in a “normal tone of
voice.” Id. at 859–60. Our reasoning sounded in the Sixth
Amendment. We observed that the voice identification testi-
mony had transformed defense counsel into the sole witness
to a disputed fact—whether the conversation occurred—cre-
ating a conflict of interest. And because the advocate-witness
rule generally bars counsel from testifying in a particular case
without withdrawing, this conflict had the potential to de-
prive the accused of the “opportunity to challenge the

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No. 24-2725 9
testimony by presenting his own version of events.” Id. at 860.
In other words, the voice identification testimony could force
the defendant to choose between retaining his counsel and
confronting a witness against him. We found such a Hobson’s
choice intolerable.
Farias asserts that the district court committed the same
error in his trial as in Jones. We see a crucial difference: the
record is devoid of any evidence that the conversation Alar-
con overheard was either between Farias and his attorney or
private. Unlike the witness in Jones, Alarcon did not specify
whom Farias was talking to when he heard Farias’s voice. Far-
ias’s counsel could have elicited testimony on this point by
examining Alarcon outside of the jury’s presence, but he did
not do so. To support his claim, Farias instead points to the
court’s initial assumption that Alarcon overheard a conversa-
tion between Farias and his counsel. Yet the court subse-
quently disavowed that assumption, reasoning that there was
no evidence to support it.
The record available corroborates the court’s subsequent
finding. While Alarcon did not say whom he heard Farias
speaking to, he testified that Farias was speaking in a “very
loud” voice, a mode of communication incompatible with a
private conversation to which Farias’s attorney would be the
only other witness. We thus hold that the district court did not
err when it admitted Alarcon’s voice identification testimony.
B. Translated-Transcript Jury Instructions
At Farias’s trial, the district court instructed the jury from
the Seventh Circuit’s pattern instruction addressing English
transcripts of foreign language recordings. It did so without
objection from Farias and after holding several conferences to

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10 No. 24-2725
review proposed jury instructions with the government and
the defense.
The instruction apprised jurors that they could rely on
translated transcripts of the Yanez-Barrera calls as substantive
evidence. It read:
During the trial, Spanish language recordings were ad-
mitted in evidence. You were also given English tran-
scripts of those recordings so you could consider the
contents of the recordings.
[¶] It is up to you to decide whether a transcript is ac-
curate, in whole or in part. You may consider the trans-
lator’s knowledge, training, and experience, the nature
of the conversation, and the reasonableness of the
translation in light of all the evidence in the case. You
may not rely on any knowledge you may have of the
Spanish language. Rather, your consideration of the
transcripts should be based on the evidence intro-
duced in the trial.
The William J. Bauer Pattern Criminal Jury Instructions of the
Seventh Circuit § 3.15 (2023 ed.).
Farias now asserts that this instruction misstates the law
because it does not inform the jury that translated transcripts
should not receive independent evidentiary weight and that
the underlying Spanish language audio recordings are the
“primary” evidence. See United States v. Cruz-Rea, 626 F.3d
929, 936 (7th Cir. 2010); United States v. Nunez, 532 F.3d 645,
651 (7th Cir. 2008).
By way of contrast, Farias points to our pattern jury in-
struction addressing transcripts of English language record-
ings, which states: “[t]he recording[s] are the evidence of

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No. 24-2725 11
what was said and who said it. The transcripts are not evi-
dence. … In other words, you must rely on what you heard,
not what you read.” The William J. Bauer Pattern Criminal
Jury Instructions of the Seventh Circuit § 3.14 (2023 ed.).
Farias’s challenge faces an initial hurdle—our presump-
tion that the pattern jury instructions accurately state the law.
See, e.g., United States v. Foy, 50 F.4th 616, 623 (7th Cir. 2022);
United States v. Marr, 760 F.3d 733, 744 (7th Cir. 2014). Here,
we are doubtful that he could rebut the presumption because
the distinction the pattern instructions draw between English
and foreign language recordings is grounded in both founda-
tional principles of evidence and practical reality.
Begin with the law. Relevant evidence is evidence which
has any tendency to make a fact of consequence more or less
probable than it would be without the evidence. Fed. R. Evid.
401. And unless barred by federal law, the federal rules of ev-
idence, or other rules prescribed by the Supreme Court, rele-
vant evidence is admissible, Fed. R. Evid. 402, meaning the
jury may give it substantive weight.
Practically speaking, jurors can generally discern the con-
tents of English language recordings themselves. Cf. 28 U.S.C.
§ 1865 (requiring jurors read, write, speak, and understand
English). And while witness testimony may assist jurors in
understanding English conversations in certain circum-
stances, any inferences about guilt or innocence come from
considering this testimony in light of the juror’s own under-
standing of the recorded conversation. In this context, tran-
scripts of English language recordings impart no independent
evidentiary content and cannot make facts of consequence
more or less likely. So they may serve as illustrative aids, see
Fed. R. Evid. 107, but not evidence. See Neighbors, 590 F.3d at

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12 No. 24-2725
495; United States v. Holton, 116 F.3d 1536, 1542 (D.C. Cir. 1997)
(“Every circuit agrees … that, while a jury may draw infer-
ences of guilt from testimony or from a tape recording, it
should not draw such inferences from a transcript.”).
For translated transcripts of foreign language recordings,
however, this is not the case. Our law prohibits jurors from
relying on their own knowledge of foreign languages to inter-
pret foreign language recordings. See United States v. Marchan,
935 F.3d 540, 548 (7th Cir. 2019). So translated transcripts can
make facts of consequence more or less likely by imparting
information the jury may not garner from any other source—
namely, the content of the conversation. Cf. Nunez, 532 F.3d at
651 (“Transcripts of recorded conversations are a virtual ne-
cessity when the conversations take place in Spanish.”).
This is not to say that translated transcripts of foreign lan-
guage conversations are the only relevant evidence of the con-
versations. The underlying foreign language recordings are
often crucial to the jury’s assessment of the translation and the
tenor of the conversation. Even as the jury may not rely on its
foreign language skills to discern the words spoken, it may
consider the recordings’ audibility and the tone of the speak-
ers’ voices; it may also judge the identity of the speakers for
itself. Video recordings may provide yet more evidence, such
as participants’ actions, facial expressions, and lip movements
indicating who is speaking.
Indeed, the Best Evidence Rule demands that underlying
recordings be admitted into evidence before translated tran-
scripts are also offered. See Fed. R. Evid. 1002; United States v.
Chavez, 976 F.3d 1178, 1196 (10th Cir. 2020) (finding that fed-
eral courts of appeals have “established that English-

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No. 24-2725 13
translation transcripts may be admitted only where the un-
derlying foreign-language recordings are themselves in evi-
dence”).
Our observation here is limited, then: translated tran-
scripts—for which the offering party has laid a proper foun-
dation and the underlying recordings were admitted—are
substantive evidence, not simply illustrative aids.
We acknowledge that there is some tension between our
commonsense conclusion and language in some of our prior
opinions. See, e.g., Nunez, 532 F.3d at 651 (holding that trans-
lated transcripts “should not ordinarily be given independent
weight”); Cruz-Rea, 626 F.3d 929, 936 (7th Cir. 2010) (same).
We do not fully resolve the tension today, though, because
Farias waived his contention in the district court.
To preserve an objection to a jury instruction, a defendant
must state the “specific objection and the grounds for the ob-
jection before the jury retires to deliberate.” Fed. R. Crim. P.
30(d); see also United States v. Gan, 54 F.4th 467, 478 (7th Cir.
2022). If the defendant does so, we review his claim de novo.
United States v. Christophel, 92 F.4th 723, 726 (7th Cir. 2024).
Conversely, where a defendant neither objects nor affirm-
atively assents to an instruction, we review the claim for plain
error. United States v. Leal, 72 F.4th 262, 265 (7th Cir. 2023); see
Fed. R. Crim. P. 52(b). And where a defendant expressly ap-
proves an instruction—evincing more than “a simple ‘no ob-
jection’”—he waives any objection to it, precluding appellate
review entirely. Leal, 72 F.4th at 265.
The question of the transcripts’ evidentiary status first
arose in response to Farias’s objection at trial to the introduc-
tion of translated transcripts bearing alleged speaker names.

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14 No. 24-2725
Farias requested that the government “actually play the re-
cordings and let the jurors follow along on the transcript and
read it,” because “that is the evidence that we’re relying on.
Not the transcript; it’s the recordings.” The court rejected the
request, remarking, “the audio recordings themselves are ev-
idence, as are the transcripts …. So both aspects are evidence.”
But this was not the court’s last word on the subject. Per-
haps recognizing the complexity of the issue, the court char-
acterized its ruling as “advisory” and invited the parties to
“think about the issue … and/or present any additional case
law” when it reconvened the following week. Farias did not
take the court up on its offer. Still, the court advised him that
there would be additional opportunities to submit proposed
jury instructions.
One of those opportunities arrived on the third day of
trial. At a conference with Farias and the government, the
court reviewed each proposed jury instruction and gave the
parties the opportunity to object. Neither the government nor
Farias objected to pattern instruction § 3.15 (Foreign Lan-
guage Recordings/English Transcripts). The government did,
however, object to pattern instruction § 3.14 (Recorded Con-
versations/Transcripts). Specifically, it contended that § 3.14’s
statement that “[t]he transcripts are not evidence” would con-
fuse the jury, because the jury was only receiving transcripts
of Spanish-language conversations, which operate differ-
ently. Farias did not oppose the government’s objection. So
with the agreement of the parties, the court struck the lan-
guage from pattern instruction § 3.14 that Farias now con-
tends was error to omit from § 3.15.
Yet even this conference did not conclude the matter. The
next morning the court asked defense counsel whether he had

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No. 24-2725 15
“[a]nything—any issue, objection, or revision on behalf of the
defense to adding the instructions or the verdict form?”
Counsel responded in the negative. And once the government
rested, the parties conferenced for a final review of the jury
instructions. The court again confirmed that Farias had no ob-
jections. Defense counsel responded for a final time: “I do not
have any objection.”
We see more than rote agreement in this record. The pre-
cise legal question Farias contests on appeal arose before the
district court: the evidentiary status of the translated tran-
scripts. With due regard to its complexity, the court repeat-
edly invited Farias to propose alternative jury instructions ad-
dressing the transcripts. He did not. And that is not all. Farias
agreed to remove from another pattern instruction the lan-
guage he now argues was essential, tacitly conceding that the
statement “the transcripts are not evidence” did not apply to
translated transcripts of Spanish language conversations. To-
gether, these actions demonstrate affirmative approval of the
court’s instruction and preclude further review of his claim.
C. Sufficiency of the Evidence
We next consider Farias’s contention that there is insuffi-
cient evidence to support his convictions. “In a sufficiency-of-
the-evidence challenge after a jury verdict, we review the ev-
idence presented at trial in the light most favorable to the gov-
ernment and draw all reasonable inferences in its favor.”
United States v. Anderson, 988 F.3d 420, 424 (7th Cir. 2021). We
will disturb the jury’s verdict only where “the record contains
no evidence, regardless of how it is weighed, from which the
jury could find guilt beyond a reasonable doubt.’” United
States v. Peoples, 119 F.4th 1097, 1101 (7th Cir. 2024) (quoting
United States v. Blassingame, 197 F.3d 271, 284 (7th Cir. 1999)).

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16 No. 24-2725
The government presented a robust case against Farias. It
called several cooperating witnesses with firsthand
knowledge of his actions, and it offered ample evidence cor-
roborating those witness’s accounts: tapes of Farias’s calls
with Yanez-Barrera, voice identification testimony from
Agents Alarcon and Betancourth, phone records showing
communications between Farias and the Texas truck dis-
patchers, and records of Farias and Martinez-Reyes’s border
crossings. Farias attempts to undermine the government’s
case by critiquing the credibility of the cooperating witnesses.
But his arguments misapprehend our role. We may not sec-
ond-guess the jury’s credibility determinations or reweigh the
evidence. United States v. Foy, 50 F.4th 616, 624 (7th Cir. 2022).
We hold that a rational jury could find Farias guilty be-
yond a reasonable doubt.
D. Sentencing
Satisfied that Farias’s conviction is sound, we turn to his
sentence. Farias alleges that the district court overestimated
the quantity of drugs he trafficked and improperly applied a
leader/organizer enhancement, resulting in an erroneous
Guidelines range.
We review a sentencing court’s factual findings—includ-
ing its drug quantity calculations—for clear error. United
States v. Mireles, 116 F.4th 713, 728–29 (7th Cir. 2024). Our re-
view of whether the facts adequately support the application
of a sentencing enhancement is plenary. United States v. Craft,
99 F.4th 407, 414 (7th Cir. 2024).
1. Drug Quantity Calculations
In service of proportional sentencing of drug offenses, the
United States Sentencing Guidelines tie the severity of a

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No. 24-2725 17
defendant’s punishment to the quantity of drugs he traf-
ficked, among other factors. See U.S.S.G § 2D1.1, cmt. backg’d
(stating that § 2D1.1 provides for “a logical sentencing struc-
ture for drug offenses”); see also United States v. Saunders, 826
F.3d 363, 374 (7th Cir. 2016) (explaining how for “drug-related
offenses, … the quantity of narcotics involved is an essential
part of the sentencing analysis, as it is often a large determi-
nant of the base offense level”).
Under the Guidelines, drug conspiracy defendants are
held responsible for the quantity of drugs directly attributable
to them, as well as amounts reasonably foreseeable from the
dealings of their co-conspirators. United States v. Jones, 56
F.4th 455, 506 (7th Cir. 2022); see also U.S.S.G § 1B1.3(a)(1)(B).
Determining this value often requires some reasoned approx-
imation. See United States v. Sewell, 780 F.3d 839, 849 (7th Cir.
2015) (explaining that drug quantity calculations need not be
“an exact science”).
When calculating drug quantities, a sentencing court may
consider a broad range of evidence—so long as the infor-
mation it relies upon possesses “indicia of reliability” and
produces a reasonable estimate. United States v. Gibson, 996
F.3d 451, 464 (7th Cir. 2021) (quoting United States v. Bozovich,
782 F.3d 814, 818 (7th Cir. 2015)). Relevant inputs can include
(but are not limited to): the quantity of drugs or proceeds
seized by law enforcement, financial or other records of the
conspiracy, co-conspirator testimony, similar transactions or-
chestrated by the defendant, and the physical capabilities of
trafficking instrumentalities, such as labs and bottles. See, e.g.,
Gibson, 996 F.3d at 464; Sewell, 780 F.3d at 849; Saunders, 826
F.3d at 375.

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18 No. 24-2725
The court found 130 kilograms of heroin and 45 kilograms
of cocaine attributable to Farias’s offense conduct. Of those to-
tals, 41.9 kilograms of heroin and 16.96 kilograms of cocaine
are not disputed, as the government seized those amounts
from the conspiracy. But Farias denies responsibility for any
drugs not seized, protesting that the court grounded its esti-
mation in unreliable evidence. We are not persuaded.
Martinez-Reyes testified that Farias directed the transport
of four unseized drug shipments to the Naperville Ware-
house, each containing between 10 and 20 kilograms of her-
oin, and three to four additional unseized shipments to the
Sugar Grove Warehouse and Harrison Street Lot. As for the
cocaine, Muñoz testified that he received three shipments
from Farias at his shop and that each shipment contained ap-
proximately 15-16 bricks. Crediting this testimony, the district
court conservatively estimated that 88.1 kilograms of un-
seized heroin and 28.04 kilograms of unseized cocaine were
attributable to Farias.
Farias faces an uphill climb in his attempt to unsettle the
district court’s calculations because a court’s credibility find-
ing “can virtually never be clear error.’” United States v.
Turner, 604 F.3d 381, 385 (7th Cir. 2010) (quoting United States
v. Pulley, 601 F.3d 660, 661–62 (7th Cir. 2010)). This is not one
of the rare cases where it is.
Martinez-Reyes’s and Muñoz’s testimony was consistent
with the drug quantities and cash proceeds seized by law en-
forcement. It was also consistent with video evidence of Mar-
tinez-Reyes unloading tractors at Sugar Grove and Harrison
Street and the size of the traps in the tractor-trailers Farias em-
ployed. These corroborating facts, together with the district
court’s express credibility determinations, assure us that the

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No. 24-2725 19
court grounded its drug calculations in evidence with “indi-
cia of reliability” and reached a reasonable estimate. See Gib-
son, 996 F.3d at 464; cf. United States v. Helding, 948 F.3d 864
(7th Cir. 2020) (reversing where a sentencing court relied on
uncorroborated testimony from confidential informants with-
out assessing their statements for reliability).
None of Farias’s arguments to the contrary succeed. That
Martinez-Reyes knew how many drugs had been seized from
the Sugar Grove Warehouse and Harrison Street Lot does not
render his testimony suspect. If anything, his deep knowledge
of the trafficking scheme adds to his credibility. Martinez-
Reyes’s questionable testimony on other subjects also does
not bar the district court from crediting his drug quantity tes-
timony. See United States v. Austin, 806 F.3d 425, 432–33 (7th
Cir. 2015) (explaining that a sentencing judge may find a wit-
ness’s drug quantity testimony credible, even where the wit-
ness “outright lied” about other matters). Finally, while it is
true that Martinez-Reyes and Muñoz testified to ranges of
trafficked drugs, not exact quantities, our law is clear that
courts “may rely upon ambiguous testimony to estimate drug
quantity.” Id. at 431.
In short, we find no clear error in the district court’s drug
quantity calculations.
2. Aggravating Role Enhancement
The United States Sentencing Guidelines provide for en-
hanced penalties for defendants who played an aggravating
role in a criminal enterprise. See U.S.S.G. § 3B1.1. The Guide-
lines instruct that an “organizer” or “leader” of criminal ac-
tivity involving five or more participants receives a four-level
enhancement. § 3B1.1(a); United States v. Weaver, 716 F.3d 439,

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20 No. 24-2725
442 (7th Cir. 2013). In comparison, a “manager” or “supervi-
sor” of such a scheme receives a three-level enhancement.
§ 3B1.1(b).
While the Guidelines do not expressly define “leader,”
“organizer,” “manager,” or “supervisor,” we have explained
that commonsense judgments about a defendant’s relative
culpability within a conspiracy ought to drive the application
of an aggravating role enhancement. United States v. Barnes,
141 F.4th 882, 888 (7th Cir. 2025). “[A] manager or supervisor
should be straightforwardly understood as simply someone
who helps manage or supervise a criminal scheme.” United
States v. Grigsby, 692 F.3d 778, 790 (7th Cir. 2012). And a leader
or organizer exercises “a greater extent of authority than a su-
pervisor or manager.” United States v. McGee, 985 F.3d 559, 562
(7th Cir. 2021); see also United States v. Colon, 919 F.3d 510, 518
(7th Cir. 2019).
Indications of authority may include the defendant’s abil-
ity to make decisions for the conspiracy, his extensive partic-
ipation in the scheme, his efforts to recruit accomplices, his
exercise of control over others, and his claim to a larger share
of the conspiracy’s proceeds. No one factor is determinative.
See U.S.S.G. § 3B1.1, cmt. n.4; see also Anderson, 988 F.3d at 428.
The record below clearly supports the district court’s de-
termination that Farias was a leader of the Chicagoland drug
trafficking scheme. He exercised substantial authority over
the direction of the scheme and his co-conspirators, facilitat-
ing Martinez-Reyes’s travel to Illinois on several occasions,
personally teaching co-conspirators how to disassemble trac-
tor trailers, arranging trucking contracts and warehouse loca-
tions, overseeing day-to-day unloading and distribution of
millions of doses of narcotics, and directing how much of the

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No. 24-2725 21
drug proceeds should remain with the Illinois co-conspira-
tors. In other words, the government offered abundant evi-
dence that Farias was leader of the trafficking organization’s
Chicago operation, with his hands in all aspects of delivery
and distribution.
Farias’s attempt to evade this conclusion by casting him-
self as a mere “logistics manager” is unavailing. Drug traffick-
ing is a logistics business—so if Farias was the logistics man-
ager for a large region, like Northern Illinois, he was a leader.
* * *
The judgment of the district court is
AFFIRMED.

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