United States v. Jose Medina De La Cruz
692 F. App'x 316
| 8th Cir. | 2017Background
- Jose Francisco Medina De La Cruz pleaded guilty to one count of conspiracy to distribute methamphetamine under 21 U.S.C. §§ 841 and 846.
- The Sentencing Guidelines range calculated was 262 to 327 months.
- At sentencing, De La Cruz presented mitigating evidence, including his daughter’s serious illness, and requested a 10-year (120-month) sentence.
- The district court (Chief Judge John A. Jarvey) imposed a below-Guidelines sentence of 220 months.
- De La Cruz appealed, arguing the 220-month sentence was substantively unreasonable because the court failed to give sufficient weight to his personal circumstances and motivations.
- The Eighth Circuit reviewed for abuse of discretion and considered whether the district court properly weighed § 3553(a) factors when declining to vary downward further.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 220-month sentence is substantively unreasonable | De La Cruz: court failed to adequately weigh his character and motives (helping ill daughter), so sentence is greater than necessary | Government: district court considered the § 3553(a) factors and reasonably declined a further downward variance | No abuse of discretion; sentence is substantively reasonable |
Key Cases Cited
- United States v. Feemster, 572 F.3d 455 (en banc) (standard: abuse of discretion for substantive reasonableness review)
- United States v. Lozoya, 623 F.3d 624 (describing when a sentence is substantively unreasonable)
- United States v. Watson, 480 F.3d 1175 (quoting factors for substantive-reasonableness review)
- United States v. French, 719 F.3d 1002 (noting narrow, deferential substantive review)
- United States v. Kelley, 652 F.3d 915 (same principle of deference in substantive review)
- United States v. Ali, 799 F.3d 1008 (below-Guidelines variance rarely an abuse of discretion)
- United States v. Zauner, 688 F.3d 426 (similar: near-impossibility of reversing modest downward variance)
- United States v. Adams, 820 F.3d 317 (district court has wide latitude in weighing § 3553(a) factors)