United States v. Hector Castaneda, 77 F.4th 611

In 1997 Castaneda was charged in a large heroin conspiracy; after release on bond he fled the U.S. and lived as a fugitive in Mexico for 20+ years; he returned in 2019 and pleaded guilty to attempt and conspiracy to possess >1 kg heroin.
Both counts carried statutory mandatory minimums (10 years imprisonment; 5 years supervised release), but Castaneda qualified for the statutory "safety valve" (18 U.S.C. § 3553(f)), which removes those mandatory minimums when five statutory criteria are met.
The Presentence Investigation Report (PSR) acknowledged safety-valve eligibility but nonetheless listed the supervised-release guideline range as 5 years to life (rather than the correct 2–5 years for Class A felonies absent the statutory minimum).
Neither Castaneda nor the district court (nor the government) objected to that supervised-release range at sentencing; the court imposed 12 years imprisonment and 5 years supervised release.
On appeal the Seventh Circuit concluded the PSR miscalculated the guideline range, the district court misstated and failed to address the safety-valve issue, and the court did not adequately explain the chosen sentence; the judgment was vacated and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Supervised-release guideline miscalculation	Govt: Castaneda waived review by not objecting at sentencing	Castaneda: Failure to object is forfeiture (not waiver); plain-error review applies and error affected substantial rights	Failure to object was forfeiture; plain-error review applies; error was clear, affected substantial rights; vacated and remanded
Failure to address safety-valve mitigation and misunderstanding of its effect	Govt: Court considered safety-valve permissively and sentence was within discretion	Castaneda: Court skipped safety-valve argument, misconstrued law (treated relief as optional), and gave no reason for upward placement	Court failed to address safety-valve properly, appeared not to understand its mandatory effect when applicable, and gave no adequate explanation; vacated and remanded
Adequacy of sentencing explanation for a within-guidelines sentence above 24 months	Govt: District court’s brief comments were sufficient	Castaneda: No stated reasons for imposing sentence above mandatory minimum and within range; prevents meaningful appellate review	Court did not state reasons required by law for sentencing at that point in the range; lack of explanation warrants reversal and remand

United States v. Wylie, 991 F.3d 861 (7th Cir. 2021) (plain-error review and significance of erroneous supervised-release term)
United States v. Hyatt, 28 F.4th 776 (7th Cir. 2022) (distinguishing waiver from mere failure to object to PSR)
United States v. Hammond, 996 F.3d 374 (7th Cir. 2021) (liberal construction of waiver principle in favor of defendant)
United States v. Barr, 960 F.3d 906 (7th Cir. 2020) (standard for review of adequacy of sentencing explanation)
United States v. Gary, 613 F.3d 706 (7th Cir. 2010) (court may summarily reject routine "stock" mitigation arguments)
United States v. Starko, 735 F.3d 989 (7th Cir. 2013) (district court cannot ignore a defendant’s principal mitigation arguments)
United States v. Bustos, 912 F.3d 1059 (7th Cir. 2019) (recognizing implicit rejection of mitigation arguments)
United States v. Washington, 739 F.3d 1080 (7th Cir. 2014) (requirement to state reason for imposing particular point within guideline range)
Gall v. United States, 552 U.S. 38 (2007) (appellate court’s role in meaningful review of sentencing explanations)