Carrell Johnson pleaded guilty after he and a partner robbed an Atlanta pharmacy and escaped in a stolen car. The driver rammed a police vehicle, sped through traffic during pursuit, and crashed into a power pole; Johnson fled from the wreck on foot. The district court imposed a two-level enhancement under U.S.S.G. § 3C1.2 for recklessly creating a substantial risk of death or serious injury during flight. The Eleventh Circuit vacated the sentence and remanded. Under United States v. Cook, a passenger’s presence in a getaway car, participation in the robbery, or later flight is not enough by itself. The Government had to prove that Johnson directly engaged in, or actively aided, counseled, induced, procured, or willfully caused the driver’s reckless conduct. The district court also had to make a specific finding under the Guideline’s application note. Because it made no such finding, the court directed resentencing based on what Johnson could see when he entered the car and whether that evidence established active responsibility.