United States v. Emiliano Palma-Meza, 685 F. App'x 806

Palma-Meza was a crewmember (“mariner”) on a three-person go-fast vessel intercepted in international waters carrying ~480 kg of cocaine.
His duties included driving the vessel, changing fuel lines, and assisting in jettisoning the cocaine when authorities approached.
He pleaded guilty to drug-trafficking offenses under 46 U.S.C. § 70503(a) and was sentenced to 135 months (low end of the Guidelines range).
He moved for a two-level minor-role reduction under U.S.S.G. § 3B1.2(b), relying on Amendment 794’s factors (limited understanding, no planning/decision-making, minimal financial stake).
The district court denied the reduction, citing drug quantity, small crew size (three persons), and Palma-Meza’s intelligence/education/work history as indicating he was not a minor participant.
Palma-Meza appealed, arguing the court applied impermissible categorical rules (especially treating large drug quantity as dispositive) and misapplied Amendment 794/De Varon guidance.

Issue	Palma-Meza’s Argument	Government’s Argument	Held
Whether the district court erred in denying a § 3B1.2(b) two-level minor-role reduction	Palma-Meza: he was less culpable than the other crewmembers, had limited understanding/authority, and Amendment 794 supports reduction even for paid couriers	Court: facts (480 kg, three-person crew, his duties and background) show his role was not substantially less culpable; district court properly considered Amendment 794 factors	Affirmed: no clear error; district court permissibly weighed drug quantity, crew size, and his background under totality of circumstances

United States v. Cruickshank, 837 F.3d 1182 (11th Cir. 2016) (Clarifies Amendment 794 is interpretive; drug quantity may be considered but is not dispositive)
United States v. De Varon, 175 F.3d 930 (11th Cir. 1999) (Sets two-principle test: role in relevant conduct and comparative role among other participants; lists relevant factors for couriers)