United States v. Edwin Peralta-Castro
699 F. App'x 407
| 5th Cir. | 2017Background
- Defendant Edwin Jassiel Peralta-Castro pleaded guilty to engaging in a monetary transaction in property derived from specified unlawful activity (money laundering).
- District court found, based on Peralta-Castro’s factual-basis admissions and the presentence report, that he aided and abetted drug trafficking by facilitating transport of three vehicles loaded with drugs.
- The court treated the drug-trafficking role as relevant conduct under U.S.S.G. § 2S1.1(a)(1) when calculating the base offense level.
- Peralta-Castro sought a mitigating-role (minor/lesser participant) adjustment under Application Note 2(C) to § 2S1.1, arguing the court misapplied that note.
- He also challenged the substantive reasonableness of his within-Guidelines 120-month sentence, arguing a much lower sentence would satisfy 18 U.S.C. § 3553(a) factors.
- The Fifth Circuit affirmed: it found no clear error in the relevant-conduct finding, held Peralta-Castro waived several claims for inadequate briefing, and upheld denial of a mitigating-role adjustment and the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Relevant-conduct attribution of drug trafficking | N/A (government sought attribution) | Peralta-Castro argued he should not be held accountable for drug trafficking as relevant conduct | Court: No clear error — admissions and PSR support aiding/abetting finding; relevant conduct properly applied under § 2S1.1(a)(1) |
| Application of Application Note 2(C) (mitigating-role adjustment) | N/A | Peralta-Castro argued the court misapplied the note and he was a minor participant | Court: Waived for inadequate briefing; alternatively, no clear error — his central role justified denial |
| Substantive reasonableness of 120-month sentence | N/A | Peralta-Castro argued a 15–21 month sentence would satisfy § 3553(a) | Court: Waived for inadequate briefing; within-Guidelines sentence is presumptively reasonable and he failed to rebut presumption |
| Procedural claim of guideline calculation error | N/A | Peralta-Castro contended base offense level miscalculated due to misattribution of conduct | Court: No error — base level calculation upheld given relevant-conduct finding |
Key Cases Cited
- United States v. King, 773 F.3d 48 (5th Cir.) (supporting inference of aiding/abetting from defendant admissions)
- United States v. Zuniga, 720 F.3d 587 (5th Cir.) (aiding and abetting relevant-conduct analysis)
- United States v. Cessa, 785 F.3d 165 (5th Cir.) (application of § 2S1.1 and role adjustments)
- United States v. Scroggins, 599 F.3d 433 (5th Cir.) (waiver for inadequate briefing)
- United States v. Stanford, 823 F.3d 814 (5th Cir.) (denial of mitigating-role adjustment where defendant had central role)
- United States v. Campos-Maldonado, 531 F.3d 337 (5th Cir.) (presumption of reasonableness for within-Guidelines sentences)
- United States v. Cooks, 589 F.3d 173 (5th Cir.) (standard for rebutting presumption of reasonableness)
- Beasley v. McCotter, 798 F.2d 116 (5th Cir.) (no liberal construction of arguments for represented parties)