United States v. John Guevara-Rosado, 24-3584

John Guevara-Rosado was originally convicted in Puerto Rico for a federal drug offense and was sentenced to prison, followed by supervised release.
After his release, his supervised release was transferred to Ohio, where he moved in with relatives.
Less than a year into his supervised release, Guevara-Rosado was implicated in a cocaine trafficking scheme involving packages sent from Puerto Rico to Ohio.
He pleaded guilty to new federal drug charges and admitted to violating the terms of his supervised release.
The district court held a consolidated sentencing hearing and imposed separate sentences for the new crimes (30 months) and for the supervised release violation (24 months), ordering them to run consecutively.
On appeal, Guevara-Rosado argued the court did not adequately explain why it imposed consecutive rather than concurrent sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of Sentencing Explanation	Court did not sufficiently explain its rationale for consecutive sentences.	The court considered the appropriate guidelines and factors, and explained its reasoning clearly.	No plain error; explanation was adequate under the law.
Whether Citation to Specific Guidelines Required	Failure to mention U.S.S.G. § 5G1.3 was reversible error.	The relevant policy statement was § 7B1.3, which the court addressed; § 5G1.3 is not mandatory in this context.	No error; court only needed to make reasoning generally clear, not to cite every guideline.
Substantive Unreasonableness of Consecutive Terms	Consecutive sentences for related conduct are excessive punishment and result in too long a sentence.	The sentences address separate harms: new crimes and breach of trust from prior release; both were within guidelines.	Sentence presumed reasonable as within guidelines and not shown to be substantively unreasonable.
Weight Given to Prior Offense	Prior offense had "outsized" impact on length and calculation of sentence for both new and old offenses.	Prior offense was properly weighed alongside recidivism and failure to be deterred; mitigating factors were also considered.	Court properly considered all relevant factors in arriving at its sentence.

United States v. King, 914 F.3d 1021 (6th Cir. 2019) (plain error review where no sentencing objection below)
United States v. Parrish, 915 F.3d 1043 (6th Cir. 2019) (standards for procedural and substantive sentencing reasonableness)
United States v. Johnson, 640 F.3d 195 (6th Cir. 2011) (discretion regarding consecutive vs concurrent sentences)
United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (presumption of reasonableness for within-guidelines sentences)
Gall v. United States, 552 U.S. 38 (2007) (standard for reasonableness of sentences)