United States v. Guadalupe Hernandez-Rios
24-1716
6th Cir.Mar 11, 2025Background
- Guadalupe Hernandez-Rios, a Mexican citizen, unlawfully entered the U.S. multiple times and was removed on five occasions between 2008 and 2017.
- He has an extensive criminal history in the U.S., including convictions for driving while intoxicated, domestic violence, using false documents, and prior reentry offenses.
- In January 2024, Hernandez-Rios was arrested after a traffic stop for impaired driving, leading to discovery of his unauthorized presence and outstanding warrants.
- He pleaded guilty to felony reentry under 8 U.S.C. § 1326(a), (b)(1).
- The district court sentenced him to 28 months’ imprisonment, within the advisory Guidelines range, which he appealed as unreasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural Reasonableness of Sentence | Court failed to give sufficient explanation of why 28 months was sufficient but not greater than necessary | Sentence properly explained and factors considered | Sentence was procedurally reasonable; no error |
| Substantive Reasonableness of Sentence | Court gave inadequate weight to mitigating factors | Sentence within Guidelines, appropriate consideration of all factors | Sentence substantively reasonable; Guidelines sentence presumed reasonable |
Key Cases Cited
- United States v. Rayyan, 885 F.3d 436 (6th Cir. 2018) (sets standards for procedural and substantive reasonableness review of criminal sentences)
- United States v. Blackwell, 459 F.3d 739 (6th Cir. 2006) (court is not required to recite § 3553(a) factors explicitly)
- Rita v. United States, 551 U.S. 338 (2007) (discusses sentencing explanations and appellate review)
- Chavez-Meza v. United States, 585 U.S. 109 (2018) (how much explanation is required for sentencing varies with case circumstances)
- United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (district court must consider arguments and evidence at sentencing)
