United States v. Eric Brenes-Colon, 136 F.4th 1343

Eric Brenes-Colon was arrested as part of an investigation into drug and firearm trafficking.
He obtained large quantities of cocaine from Puerto Rico and provided them to a co-conspirator for distribution.
Law enforcement found substantial quantities of cocaine, marijuana, MDMA, cash, and a firearm at the residence linked to Brenes-Colon.
Brenes-Colon pleaded guilty to conspiracy to distribute and possession with intent to distribute significant quantities of cocaine and MDMA.
At sentencing, the District Court commented on the overall harmfulness of illegal drugs, citing its experience.
The court sentenced Brenes-Colon to 108 months’ imprisonment, within the Guidelines range; he appealed, arguing procedural error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the District Court committed procedural error by referencing an allegedly erroneous fact about drug deaths at sentencing	The court relied on a clearly erroneous factual statement not supported by the record, making the sentence unreasonable	The court may rely on its experience, common sense, and need not be confined to record evidence; the volume of drugs was the main consideration	No plain error; court's experience and judgment justified, and the outcome would not be different absent the statement

United States v. Rodriguez, 75 F.4th 1231 (11th Cir. 2023) (establishing abuse-of-discretion standard for reviewing sentence reasonableness)
United States v. Steiger, 107 F.4th 1315 (11th Cir. 2024) (sentences unobjected to below reviewed for plain error)
United States v. Shaw, 560 F.3d 1230 (11th Cir. 2009) (sentencing judges are not limited to the record and may rely on institutional knowledge)
United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015) (district courts can draw on experience, common sense, and good judgment at sentencing)
United States v. Philidor, 717 F.3d 883 (11th Cir. 2013) (judges may infer facts at sentencing based on ordinary human experience)