United States v. Gelacio Cendejas-Renteria
699 F. App'x 392
| 5th Cir. | 2017Background
- Defendant Gelacio Cendejas-Renteria was sentenced to life imprisonment after conviction for possession with intent to distribute 500 grams or more of methamphetamine.
- The sentence was within the Guidelines range computed by the district court.
- Cendejas-Renteria appealed, arguing the sentence was procedurally and substantively unreasonable under Gall v. United States.
- He did not raise his procedural or substantive objections in the district court, so the Fifth Circuit applied plain-error review.
- The district court heard argument, considered objections and a downward-departure request, and stated the sentence satisfied the § 3553(a) factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural error: adequacy of sentencing explanation | Cendejas-Renteria argued the district court’s brief explanation was inadequate | Government argued the court sufficiently explained and considered arguments and objections | No plain procedural error; explanation adequate and failure to add more reasons did not affect substantial rights |
| Substantive reasonableness of within-Guidelines life sentence | Cendejas-Renteria argued the sentence was substantively unreasonable and improperly balanced § 3553(a) factors | Government argued within-Guidelines sentences are presumptively reasonable and the court made an individualized assessment | Affirmed: presumption not rebutted; defendant merely asks court to reweigh factors, which appellate court will not do |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (2007) (standards for procedural and substantive reasonableness review of sentences)
- Rita v. United States, 551 U.S. 338 (2007) (explanation requirement for within-Guidelines sentences)
- Puckett v. United States, 556 U.S. 129 (2009) (plain-error standard and remedy discretion)
- United States v. Mondragon-Santiago, 564 F.3d 357 (5th Cir. 2009) (appellate review of procedural and substantive challenges to within-Guidelines sentences)
- United States v. Peltier, 505 F.3d 389 (5th Cir. 2007) (plain-error review when objections not raised below)
- United States v. Cooks, 589 F.3d 173 (5th Cir. 2009) (how to rebut presumption of reasonableness for within-Guidelines sentences)