United States v. Juan Anguiano-Guerrero
714 F. App'x 148
| 3rd Cir. | 2017Background
- Juan Carlos Anguiano-Guerrero, a Mexican citizen and lawful permanent resident since 2004, was deported after a manslaughter conviction and later convicted multiple times for illegal reentry under 8 U.S.C. § 1326(a).
- After an earlier illegal-reentry conviction (42 months) and subsequent deportation, ICE arrested Anguiano in Pennsylvania on June 29, 2016, and charged him again with illegal reentry.
- The Presentence Report: base offense level 8, +4 for prior illegal reentry, +10 for the manslaughter conviction, -3 for acceptance — total offense level 19; criminal history category III; Guidelines range 37–46 months.
- The District Court sentenced Anguiano to 46 months (top of Guidelines). Anguiano did not object at sentencing and appealed, arguing the court procedurally erred by failing to acknowledge four mitigating arguments in his sentencing memorandum.
- The Government sought the high-end sentence as deterrence for repeated reentry; Anguiano urged a low-end sentence citing good character, timing/circumstances of manslaughter, harsher prison conditions due to immigration detainer, and lack of motivation to return.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court procedurally erred by failing to address four mitigating arguments | Anguiano: court failed to acknowledge and meaningfully consider four arguments supporting a lower Guidelines sentence | Government: court sufficiently considered non-frivolous arguments and need not address unsupported claims | No plain error; court adequately stated reasons and considered arguments supported by record |
| Whether plain-error review applies | Anguiano: appeals sentence without contemporaneous objection | Government: Anguiano failed to object so plain-error standard governs | Plain-error standard applies because no objection was made at sentencing |
| Whether the sentence was unreasonable given § 3553(a) factors | Anguiano: mitigation warranted lower sentence | Government: recidivism and seriousness justify high-end Guidelines sentence | Within-Guidelines sentence presumed reasonable; district court’s explanation adequate |
| Whether certain mitigating claims had factual basis requiring discussion | Anguiano: claimed financial support of children and disparate prison treatment merit consideration | Government: those claims lack factual support or merit | Court not required to address unsupported or meritless arguments; no error in omission |
Key Cases Cited
- Rita v. United States, 551 U.S. 338 (2007) (explains sufficiency of concise sentencing statements and presumption of reasonableness for within-Guidelines sentences)
- United States v. Flores-Mejia, 759 F.3d 253 (3d Cir. 2014) (requires contemporaneous objection at sentencing to avoid plain-error review)
- United States v. Dragon, 471 F.3d 501 (3d Cir. 2006) (defines elements of plain error review)
- United States v. Olano, 507 U.S. 725 (1993) (sets forth plain-error test)