United States v. Christian Amezquita-Munoz
675 F. App'x 485
| 5th Cir. | 2017Background
- Defendant Christian Omar Amezquita-Munoz pleaded guilty to possession with intent to distribute ≥5 kg of cocaine.
- He appealed the district court’s denial of a U.S.S.G. §3E1.1 acceptance-of-responsibility reduction.
- He also challenged the district court’s use of a total drug weight of 30.17 kg in the Sentencing Guidelines calculation.
- The Presentence Report (PSR) included the 30.17 kg figure; Amezquita-Munoz did not produce evidence rebutting the PSR’s drug-weight estimate.
- The district court considered relevant conduct in the PSR; the adopted drug quantity did not raise the sentence above the statutory maximum.
- The Fifth Circuit reviewed the denial of acceptance-of-responsibility with deference and affirmed the sentencing calculations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendant should receive acceptance-of-responsibility reduction | Amezquita-Munoz argued he merited the §3E1.1 reduction | District court found insufficient evidence of sincere contrition | Denial affirmed; no basis to find court’s decision without foundation |
| Whether PSR drug-quantity estimate may be used for sentencing | Amezquita-Munoz argued drug amount is an element for jury/admission and PSR estimate unreliable | Government/district court relied on PSR and relevant-conduct authority | Affirmed use of PSR weight; defendant failed to show PSR materially untrue or unreliable |
| Whether district court erred by adopting PSR facts without inquiry | Amezquita-Munoz argued disputed facts require court resolution before use | District court relied on PSR with adequate evidentiary basis and lack of rebuttal | No clear error; court may adopt PSR facts when supported and unrebutted |
| Whether sentencing calculation exceeded statutory maximum due to relevant conduct | Amezquita-Munoz implied relevant-conduct additions improperly increased penalty | District court concluded relevant conduct did not push sentence past life maximum | Held that inclusion of relevant conduct was permissible because it did not exceed statutory maximum |
Key Cases Cited
- United States v. Buchanan, 485 F.3d 274 (5th Cir.) (deference to district court denial of acceptance-of-responsibility)
- United States v. Juarez-Duarte, 513 F.3d 204 (5th Cir.) (affirming denial standard: court will uphold unless decision is without foundation)
- United States v. Medina-Anicacio, 325 F.3d 638 (5th Cir.) (sincere contrition required for acceptance reduction)
- United States v. Betancourt, 422 F.3d 240 (5th Cir.) (standard for reviewing drug-quantity findings)
- United States v. Taylor, 277 F.3d 721 (5th Cir.) (defendant bears burden to show PSR materially untrue)
- United States v. Hernandez, 633 F.3d 370 (5th Cir.) (district court may include relevant conduct not increasing sentence beyond statutory maximum)
- United States v. Puig–Infante, 19 F.3d 929 (5th Cir.) (court may adopt PSR facts if adequately supported and unrebutted)