United States v. Eduardo Castellanos-Loya
503 F. App'x 240
| 4th Cir. | 2013Background
- Castellanos-Loya was convicted of false representation as a United States citizen under 18 U.S.C. § 911 and aggravated identity theft under § 1028A.
- The Government introduced evidence that the SSN used by Castellanos-Loya belonged to a real person and was used in conjunction with his false citizenship claim.
- Castellanos-Loya admitted guilt on the false representation charge at trial and challenged the sufficiency of evidence for the § 1028A conviction.
- The district court allowed testimony about the SSN’s date of birth after late disclosure and the court deemed any error harmless.
- Castellanos-Loya challenged an obstruction of justice enhancement under USSG § 3C1.1, arguing perjury related only to the § 1028A offense, not § 911.
- The district court imposed the § 3C1.1 enhancement, reflecting perjury during proceedings related to the charged offenses; Castellanos-Loya appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for § 1028A | Castellanos-Loya contends the SSN did not belong to a real person or that he knew it did. | Government failed to prove the SSN belonged to a real person and that Castellanos-Loya knew it. | Sustained; substantial evidence supports real-person SSN and knowledge. |
| Knowledge of real-person status | Knowledge requirement was not proven beyond a reasonable doubt. | Defendant did not verify seller's truthfulness, so knowledge could not be established. | Met; jury could infer knowledge from seller’s representation and high probability of existence. |
| Relation to offense and waiver | Evidence of SSN relation to the false-identity offense is present. | Waived because not raised in Rule 29 motion. | Waiver applied; court rejects new challenge on this point. |
| Obstruction enhancement § 3C1.1 | Perjury was related to separate offense, not the § 911 charge. | Perjury during investigation/sentencing related to instant offense; broad reading supports enhancement. | Affirmed; enhancement applies to the related conduct and findings were adequate. |
Key Cases Cited
- Castillo-Pena v. United States, 674 F.3d 318 (4th Cir. 2012) (relevant to predicate offenses and means of identification)
- Flores-Figueroa v. United States, 556 U.S. 646 (Supreme Court 2009) (knowledge mens rea for identification offenses can be inferred)
- United States v. Cameron, 573 F.3d 179 (4th Cir. 2009) (standard for substantial evidence review)
- United States v. Jones, 308 F.3d 425 (4th Cir. 2002) (broad reading of obstruction enhancement related to investigation)
- United States v. Mollner, 643 F.3d 713 (10th Cir. 2011) (scope of § 3C1.1 and closely related offenses)