Both affirmed enhancements for “substantial disruption[s].” An unpublished Tenth Circuit case, United States v. Wyrick, 416 Fed.Appx. 786 (10th Cir.2011) (unpublished), involved a district court's decision to sustain the defendant's objection to a sentence enhancement under § 2A6.1(b)(4)(A) after concluding that the “substantial disruption” requirement was not met. Wyrick, 416 Fed.Appx. at 790. The Wyrick court did not, however, reexamine the issue on appeal.

Defendant defines a "true first offender" as "a defendant who has had no previous contact with law enforcement or the judicial system." Def. Op. Br. at 7 n.2 (quoting United States v. Wyrick, 416 F. App'x 786, 787 n.1 (10th Cir. 2011) (unpublished)). The district court addressed all three of Defendant's arguments. First, the court addressed the relevant-conduct error this Court identified in Godinez-Perez I. This time, the court declined to attribute to Defendant the 887.26 grams of methamphetamine found in the storage unit.

which include his physical abuse and trauma as a youth, as well as his documented history of mental illnesses, are legitimate grounds in and of themselves for a downward variance. United States v. Wallace , 605 F.3d 477, 479 (8th Cir. 2010) (district court properly considered under 18 U.S.C. § 3553(a) the extensive physical abuse the defendant suffered as a child); United States v. Wyrick , 416 F. App'x 786 (10th Cir. 2011) (district court properly considered the role defendant's mental illness played in his offense as a factor under § 3553(a) );• The relevant charged conduct underlying Mr. Harris's guilty plea consists of about a half-dozen sales of street level, small or user quantities of a controlled substance made, not to a general member of the public, but during a carefully orchestrated series of drug sales to a confidential informant;