United States v. Castillo-Vazquez, 995 F.3d 14

In March 2018 a U.S. Coast Guard interdicted a 30-foot vessel 39 nautical miles south of Puerto Rico, seized ~900 kg of cocaine, and arrested three crew members, including Juan Carlos Castillo-Vazquez.
Castillo pleaded guilty to maritime and drug-importation offenses; initial PSR produced a 168–210 month guidelines range.
After a safety‑valve debriefing Castillo received a 2‑level reduction, yielding a 135–168 month range; he asked the court to instead impose the 120‑month statutory minimum.
Castillo sought a 2‑level minor‑role adjustment under USSG § 3B1.2(b) and a downward departure for family ties under USSG § 5H1.6; the government argued for a mid‑range sentence.
The district court sentenced Castillo to 135 months (bottom of the guidelines range), explained it denied the minor‑role adjustment citing United States v. Arias‑Mercedes and found family ties insufficient for departure; Castillo appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Minor‑role adjustment under USSG § 3B1.2(b)	Castillo: he was substantially less culpable than average participant (crew member, not captain)	Government: as a crew member on a tiny boat transporting a very large load, Castillo is not a minor participant	Denied — court properly refused adjustment; Arias‑Mercedes controls and explanation was adequate
Sufficiency of district court's explanation for denying minor‑role	Castillo: court failed to explain adequately why reduction was denied	Government: court's reference to Arias‑Mercedes and awareness of 900 kg sufficed for meaningful appellate review	Denied — no requirement to recite Application Note 3(C); explanation adequate for review
Downward departure for family ties under USSG § 5H1.6	Castillo: family ties and responsibilities warrant a departure	Government: departure discretionary and not warranted on facts	Denied — refusal to depart is discretionary and largely unreviewable when court knows it has authority to depart

United States v. Arias-Mercedes, 901 F.3d 1 (1st Cir. 2018) (refusal to grant minor‑role reduction for crew member on small boat with large drug quantity)
Gall v. United States, 552 U.S. 38 (2007) (sentencing court must provide sufficient explanation to allow meaningful appellate review)
United States v. Mendoza-Maisonet, 962 F.3d 1 (1st Cir. 2020) (no requirement to list Application Note 3(C) factors when denying minor‑role adjustment)
United States v. Reyes-Torres, 979 F.3d 1 (1st Cir. 2020) (standard of review for sentencing: factual findings clear error, guidelines interpretation de novo, judgment calls abuse of discretion)
United States v. Sanchez, 354 F.3d 70 (1st Cir. 2004) (discretionary refusal to depart is generally unreviewable)
United States v. Teeter, 257 F.3d 14 (1st Cir. 2001) (appellate court foreclosed from second‑guessing district court's deliberate decision not to depart)
United States v. Louis, 300 F.3d 78 (1st Cir. 2002) (district court's rejection of a downward departure is largely unreviewable)
United States v. Zannino, 895 F.2d 1 (1st Cir. 1990) (issues inadequately argued are waived)