United States v. Eulogio Ramiro Yoza Tigua, 963 F.3d 1138

Tigua and Castro were crewmembers on a go-fast boat intercepted by the U.S. Coast Guard with ~846 kg of cocaine recovered; both pleaded guilty to maritime drug offenses.
Their guilty pleas were accepted (adjudications of guilt) in October 2018, before the First Step Act’s enactment on December 21, 2018.
Prior to the First Step Act, the statutory safety-valve did not apply to maritime drug offenses, so first-time offenders with ≥5 kg cocaine faced a 120-month mandatory minimum.
The First Step Act amended 18 U.S.C. § 3553(f) to cover maritime offenses but limited the amendment to convictions “entered on or after” its enactment.
The district court held the Act inapplicable because the defendants’ convictions were entered (adjudications of guilt) before December 21, 2018, and denied Castro a two‑level minor-role reduction; both defendants were sentenced to the 120‑month statutory minimum.
On appeal the Eleventh Circuit affirmed: “conviction entered” means the adjudication of guilt (date plea was accepted), not the later imposition of sentence; and any error denying Castro a minor‑role reduction was harmless due to the mandatory minimum.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants whose pleas were accepted before Dec. 21, 2018 but sentenced after that date qualify for the First Step Act’s amended safety‑valve (§ 3553(f)).	"Conviction entered" means the judgment of conviction (plea + sentencing); because sentencing occurred after enactment, defendants qualify.	"Conviction entered" means the adjudication of guilt (plea acceptance); convictions occurred before enactment, so the amendment does not apply.	Affirmed: "conviction entered" means adjudication of guilt; defendants ineligible for safety‑valve relief.
Whether Castro was entitled to a two‑level minor‑role reduction under U.S.S.G. § 3B1.2(b).	Castro: he played a minor role and should receive a two‑level reduction.	District court/Gov: factual record shows active participation; reduction not warranted; even if error, mandatory minimum controls.	Affirmed: denial not reversible (any error harmless) because statutory mandatory minimum precluded a lower sentence.

Deal v. United States, 508 U.S. 129 (1993) (interpreting multiple meanings of “conviction” and emphasizing contextual reading).
Dorsey v. United States, 567 U.S. 260 (2012) (policy‑based application of a sentencing reform when text ambiguous).
United States v. Castillo, 899 F.3d 1208 (11th Cir. 2018) (safety‑valve did not apply to maritime drug trafficking pre‑First Step Act).
United States v. Cabezas‑Montano, 949 F.3d 567 (11th Cir. 2020) (defendants conceded ineligibility when convicted before amendment).
Taniguchi v. Kan Pac. Saipan, Ltd., 566 U.S. 560 (2012) (start statutory interpretation with ordinary meaning of words).
United States v. Castaing‑Sosa, 530 F.3d 1358 (11th Cir. 2008) (cannot impose sentence below statutory minimum absent § 3553(e)/§ 5K1.1 substantial‑assistance or safety‑valve under § 3553(f)).
United States v. Rodriguez De Varon, 175 F.3d 930 (11th Cir. 1999) (review of factual findings about role in the offense for clear error).