The office manager of a nonprofit organization who steals funds from the agency is not in a “position of trust” that justifies an enhancement of her sentence upon conviction, the Court of Appeals for the District of Columbia has ruled. Although she occupied a position of trust “in the colloquial sense that she was not to use her access for nefarious purposes,” her position was not characterized by professional or managerial discretion with little or no supervision. A woman was hired as office manager for the D.C. Center for Independent Living in 1998 and a year or so later the Executive Director noticed that some of the cancelled checks did not match the descriptions in the ledger. When...