United States v. Juan Guerrero-Deleon, 713 F. App'x 163

Guerrero-Deleon and Suazo-Molina were arrested after a controlled buy at a Denny’s; police recovered ~2 pounds of methamphetamine from the van they arrived in.
Suazo-Molina arranged the sale; Guerrero-Deleon admitted he was paid $1,000 to assist with the delivery and overheard discussions indicating others were involved.
Guerrero-Deleon pled guilty to conspiracy to possess with intent to distribute and to distribute 500+ grams of methamphetamine under 21 U.S.C. §§ 841, 846.
Presentence Report set offense level 25, criminal history I, Guidelines range 57–71 months; statutory minimum waived under safety-valve provisions.
Guerrero-Deleon requested a U.S.S.G. § 3B1.2 mitigating-role reduction (minor or minimal participant); the district court denied the reduction and sentenced him to 53 months (low end minus time served).
On appeal, Guerrero-Deleon argued the court erred by refusing a minor-role reduction because he was a courier and less culpable than Suazo-Molina.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Guerrero-Deleon was entitled to a § 3B1.2 minor-role reduction	Guerrero-Deleon: he was a courier and less culpable than Suazo-Molina, so entitled to downward adjustment	Government: denial was proper because Guerrero-Deleon was recruited, knew scope of conspiracy, and stood to gain significant payment	Affirmed: district court did not clearly err in denying the § 3B1.2 reduction

United States v. Powell, 680 F.3d 350 (4th Cir.) (review of district court factual findings for clear error)
United States v. Hassan, 742 F.3d 104 (4th Cir.) (mitigating-role reduction not automatic for least culpable conspirator)
United States v. Pratt, 239 F.3d 640 (4th Cir.) (defendant must prove by preponderance entitlement to role reduction)
United States v. Self, 681 F.3d 190 (3d Cir.) (couriers may be essential to drug conspiracies)
United States v. Bello-Sanchez, 872 F.3d 260 (5th Cir.) (courier’s role as a factor in § 3B1.2 analysis)
United States v. Morosco, 822 F.3d 1 (1st Cir.) (courier status considered in role reduction analysis)
United States v. Reavis, 48 F.3d 763 (4th Cir.) (importance of defendant’s understanding of conspiracy scope)
United States v. Kiulin, 360 F.3d 456 (4th Cir.) (consideration of drug quantity and payment in role analysis)
United States v. Cruickshank, 837 F.3d 1182 (11th Cir.) (amount, value, and payment to courier relevant to § 3B1.2)
United States v. De Varon, 175 F.3d 930 (11th Cir.) (listing factors relevant to courier’s entitlement to reduction)