United States v. Jose Meza-Lopez, 2015 U.S. App. LEXIS 22193

Jose Luis Meza-Lopez, an undocumented immigrant, pled guilty to conspiracy to distribute ≥500 grams of methamphetamine (21 U.S.C. § 846) and conspiracy to launder money (18 U.S.C. § 1956(h)) arising from at least 17 round trips shipping methamphetamine from Phoenix, AZ to Lincoln, NE in 2013.
No plea agreement; PSR calculated total offense level 37, criminal history I, yielding an advisory Guidelines range of 210–262 months; the district court adopted the PSR.
At sentencing Meza-Lopez requested the statutory minimum (120 months), arguing his likely deportation (post‑sentence) and resulting inability to access BOP programs and supervised‑release supervision justified a downward variance/departure.
The district court imposed a within‑Guidelines sentence of 210 months (the bottom of the range), citing the quantity of methamphetamine and Meza‑Lopez’s central role in a systematic conspiracy.
Meza‑Lopez appealed, arguing the sentence was substantively unreasonable because the court failed to properly consider immigration consequences and relied on improper/extra‑record knowledge from related proceedings.
The Eighth Circuit affirmed, holding the district court did not abuse its discretion and properly considered § 3553(a) factors; immigration consequences did not warrant a downward variance and the court’s references to related proceedings were supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deportation and consequent loss of BOP programs/supervision warrant a downward variance/departure	Meza‑Lopez: deportation is a severe consequence that justifies reducing sentence to statutory minimum	Government: immigration consequences are not a basis for departure/variance absent special evidence	Court: Rejected — immigration consequences insufficient to overcome presumption that within‑Guidelines sentence is reasonable
Whether district court relied on improper or irrelevant facts from other proceedings	Meza‑Lopez: court referenced its knowledge from hearings about other conspirators and overweighted that knowledge	Government: court’s comments referred to facts in the record about the conspiracy and Meza‑Lopez’s role	Court: Rejected — references were tied to admitted conduct and appropriate § 3553(a) considerations
Whether the sentence was substantively unreasonable under § 3553(a) factors	Meza‑Lopez: weighting of factors was erroneous and resulted in an excessive sentence	Government: sentence falls within advisory Guidelines, is presumptively reasonable	Court: Affirmed — no abuse of discretion in weighing factors
Burden to show abuse of discretion on appeal	Meza‑Lopez: asserted district court plainly erred in consideration of factors	Government: defendant bears burden to show sentence substantively unreasonable	Court: Held Meza‑Lopez failed to meet his burden

United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (abuse‑of‑discretion standard for appellate review of sentences)
United States v. Sigala, 521 F.3d 849 (8th Cir. 2008) (immigration/removal consequences do not automatically justify a downward departure)
United States v. Waller, 689 F.3d 947 (8th Cir. 2012) (rare reversal for substantive unreasonableness; deference to district court)
United States v. Kane, 552 F.3d 748 (8th Cir. 2009) (identifying categories of sentencing abuse of discretion)