United States v. Gonzalez-Andino, 58 F.4th 563

Police executed a search warrant at a Manatí apartment and found multiple drugs, firearms, ammunition, paraphernalia, and cash; González was arrested in one room of the apartment.
A federal grand jury indicted codefendants on multiple drug counts and a § 924(c) firearms-in-furtherance count; González pleaded guilty to possession with intent to distribute marijuana (one count) and a § 924(c) count.
In the plea agreement González acknowledged possession of 87.23 grams of marijuana and the parties agreed to jointly recommend specific sentences (including the 60‑month § 924(c) statutory minimum); the plea contained an appeal-waiver if total imprisonment did not exceed 66 months.
The Presentence Investigation Report (PSR) converted all controlled substances found in the apartment into a 39.2‑kilogram marijuana equivalent and calculated Guidelines based on that amount. González did not object to the PSR.
The district court sentenced González to 78 months (60 months on the § 924(c) count plus 18 months on the drug count), exceeding the plea cap and preserving González’s right to appeal.
On appeal González argued procedural unreasonableness: the court failed to tie him to the PSR drug-quantity and relied on an unsupported drug-quantity attribution; the First Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation: Whether González preserved objections to the PSR drug-quantity attribution	González contended the court should not have attributed the apartment's total drugs to him and should have made an explicit finding tying quantity to his conduct	Government argued González failed to make specific objections in district court and thus forfeited these claims	Forfeited; appellate review only for plain error because González did not preserve specific objections
Sufficiency/explicit finding: Whether the district court plainly erred by attributing the apartment's total drug quantity to González without explicit, individualized findings	González argued there was no evidence he participated in a larger enterprise or that the larger quantity was attributable or foreseeable to him	Government maintained the PSR and record supported attribution (drugs, guns, cash, paraphernalia; González’s own statements suggested a stash‑house role)	No plain error: attribution was supported by the unobjected-to PSR and defendant’s own statements; although a more explicit finding would be preferable, the record sufficed to uphold the sentence

United States v. McDonald, 804 F.3d 497 (1st Cir. 2015) (district-court drug-quantity attributions under U.S.S.G. §1B1.3 are entitled to deference)
United States v. Millán-Machuca, 991 F.3d 7 (1st Cir. 2021) (plain-error review can uphold an implicit drug-attribution finding when record support is ample)
United States v. Soto-Soto, 855 F.3d 445 (1st Cir. 2017) (specificity requirement for preserving sentencing objections)
United States v. Merced-García, 24 F.4th 76 (1st Cir. 2022) (describing the high plain-error standard)
United States v. Takesian, 945 F.3d 553 (1st Cir. 2019) (plain-error review of unmade factual findings requires showing that the desired finding is the only one rationally supported)
United States v. Díaz-Rivera, 957 F.3d 20 (1st Cir. 2020) (guilty-plea cases: appellate fact-drawing from plea colloquy and unchallenged PSR)
United States v. Wood, 924 F.2d 399 (1st Cir. 1991) (supporting deference to district courts on relevant-conduct attributions)