United States v. Eulogio Carabali Montano, 20-13713

Montano was sentenced to 151 months for conspiracy to possess and possession with intent to distribute >5 kg of a cocaine-containing substance aboard a vessel; he appealed denial of a minor-role adjustment.
Three crewmembers (Montano, Angel Quinones, Joshua David McLean) knowingly participated in transporting a large cocaine shipment; all were involved in jettisoning the load when the U.S. Coast Guard approached.
Montano argued he was a mere courier/minor participant in a larger international organization and that the district court failed to properly compare his role to others and apply the §3B1.2 guideline factors.
The district court limited accountability to the crewmembers’ transportation conduct, applied Rodriguez De Varon principles, and expressly considered the guideline factors in denying a role reduction.
Montano offered no sentencing evidence identifying other co-conspirators who recruited, trained, owned the drugs, or otherwise were more culpable than the crewmembers.
The Eleventh Circuit reviewed the denial for clear error and affirmed the district court’s refusal to grant a minor-role reduction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Montano was entitled to a minor-role reduction under U.S.S.G. §3B1.2	The denial was correct because Montano knowingly participated in and performed an important transportation role	Montano claimed he was a lesser participant/courier and thus entitled to a reduction	Denied — district court did not clearly err; Montano was accountable for significant transportation conduct
Whether the district court failed to compare Montano’s role to other participants	Court properly measured Montano against relevant conduct and fellow crewmembers	Court failed to properly compare his role to participants in the broader conspiracy	Rejected — comparison is against relevant conduct and other discernable participants, not conduct of larger conspiracy
Whether the district court failed to apply guideline factors or make sufficient findings	Court expressly considered Rodriguez De Varon and guideline note factors and limited accountability to mariner conduct	Court should have made more specific findings and addressed factors more thoroughly	Rejected — courts need only state ultimate determination if record supports it; detailed findings not required

United States v. Cruickshank, 837 F.3d 1182 (11th Cir. 2016) (defendant bears burden to prove minor role; review for clear error)
United States v. Rodriguez De Varon, 175 F.3d 930 (11th Cir. 1999) (two-part framework: measure against relevant conduct and against other participants)
United States v. Martin, 803 F.3d 581 (11th Cir. 2015) (less culpable than others does not automatically entitle defendant to reduction)
United States v. Cabezas-Montano, 949 F.3d 567 (11th Cir. 2020) (absence of sentencing evidence about higher-level coconspirators undercuts minor-role claim)