United States v. Juan Castellanos Muratella, 956 F.3d 541

Castellanos pled guilty to conspiracy to distribute methamphetamine after selling over 50 grams to undercover officers in Iowa.
Presentence report showed two prior Iowa felony drug convictions under Iowa Code § 124.401.
The district court applied U.S.S.G. § 4B1.1 and designated Castellanos a career offender, raising the Guidelines range from 130–162 months to 262–327 months.
Castellanos sought a 120‑month sentence; the court imposed a below‑Guidelines sentence of 200 months plus five years’ supervised release.
On appeal Castellanos argued (1) § 124.401 is broader than the Guidelines’ definition of a “controlled substance offense” and thus cannot be a career‑offender predicate, and (2) the district court failed to treat his long‑term methamphetamine addiction as a mitigating factor.
The Eighth Circuit affirmed: it held § 124.401 fits within the Guidelines’ definition (relying on circuit precedent) and the sentence was substantively reasonable.

Issue	Castellanos' Argument	Government's Argument	Held
Whether Iowa Code § 124.401 is a career‑offender predicate under U.S.S.G. § 4B1.1	§ 124.401 criminalizes “simulated controlled substances” in addition to counterfeit substances, so it is broader than § 4B1.2 and cannot qualify	Brown and related precedent treat Iowa’s “simulated” substances as falling within the Guidelines’ concept of “counterfeit,” so § 124.401 is not broader	Affirmed: § 124.401 is no broader than § 4B1.2; career‑offender designation proper
Whether the district court failed to consider addiction as mitigation, making the sentence unreasonable	Court treated his 13‑year addiction as aggravating and failed to give adequate mitigating weight	District court acknowledged addiction as relevant and imposed a substantial downward variance from the Guidelines	Affirmed: sentencing decision was substantively reasonable; no abuse of discretion

United States v. Brown, 638 F.3d 816 (8th Cir. 2011) (held Iowa’s “simulated controlled substance” fits the Guidelines’ “counterfeit” definition)
Mathis v. United States, 136 S. Ct. 2243 (2016) (clarified categorical and modified‑categorical approaches)
Gall v. United States, 552 U.S. 38 (2007) (standards for reviewing substantive reasonableness of sentences)
United States v. Boose, 739 F.3d 1185 (8th Cir. 2014) (career‑offender classification reviewed de novo)
United States v. Boleyn, 929 F.3d 932 (8th Cir. 2019) (categorical‑approach principle for predicate offenses)
United States v. Robertson, 474 F.3d 538 (8th Cir. 2007) (plain‑meaning approach to “counterfeit” concepts)