United States v. Guzman, 664 F. App'x 120

Defendant Adalberto Ariel Guzman (age 17 at the time of the offenses) was convicted after jury trial of conspiracy to murder, two counts of murder, two counts of using a firearm during a crime of violence, and two counts of causing death by firearm.
District court sentenced Guzman to life imprisonment plus 35 years under the Sentencing Guidelines; judgment entered December 19, 2014.
Guzman appealed, arguing his adolescence and potential for rehabilitation rendered the life sentence substantively unreasonable under the Eighth Amendment and Miller-related principles.
The district court held an evidentiary hearing and explicitly considered Miller factors (age, family environment, circumstances of the homicide, possibility of rehabilitation) alongside 18 U.S.C. § 3553(a) factors.
The court relied on findings that Guzman’s crimes were brutal, calculated (not impulsive or merely peer-driven), committed when he was nearly 18, showed lack of remorse, included violent jail conduct, continued gang association, and a low likelihood of rehabilitation.
The Second Circuit reviewed the sentence for substantive reasonableness for abuse of discretion and affirmed the district court’s sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Guzman’s life-plus-35-year sentence is substantively unreasonable given his juvenile status and potential for rehabilitation	Guzman: adolescence and demonstrated possibility of reform make life sentence excessive under Miller and Eighth Amendment limits	Government: district court reasonably weighed Miller and §3553(a) factors and found life sentence appropriate given the crimes and low rehabilitation prospects	Affirmed — not substantively unreasonable; district court did not abuse discretion
Whether the district court properly applied Miller factors and §3553(a) in sentencing	Guzman: court should have given greater weight to diminished culpability and reduced relevance of retribution/deterrence for juveniles	Government: district court adequately considered age, family, offense circumstances, and rehabilitation likelihood and permissibly emphasized seriousness, deterrence, and culpability	Affirmed — court gave ample, reasonable consideration to Miller factors and §3553(a)

Roper v. Simmons, 543 U.S. 551 (prohibition on death penalty for juvenile offenders)
Graham v. Florida, 560 U.S. 48 (Eighth Amendment forbids life without parole for juveniles in nonhomicide cases)
Miller v. Alabama, 567 U.S. 460 (mandatory life without parole for juveniles convicted of homicide unconstitutional; courts must consider youth-related factors)
Cavera v. United States, 550 F.3d 180 (2d Cir.) (standard for substantive reasonableness review)
Rigas v. United States, 490 F.3d 208 (2d Cir.) (definition of range of permissible sentencing decisions)
Kimbrough v. United States, 552 U.S. 85 (sentencing courts’ discretion to consider policy and factors not strictly tied to Guidelines)
Gall v. United States, 552 U.S. 38 (deference to district courts’ sentencing judgments and §3553(a) analysis)