United States v. Juan Loaiza, 679 F. App'x 512

Loaiza participated in a large methamphetamine distribution conspiracy in Lincoln, Nebraska; testimony and a wiretap tied him to frequent visits to a stash house and to payments to couriers.
He was personally responsible for at least 9,284 grams of methamphetamine and was charged with conspiracy to distribute >500 grams of a methamphetamine mixture under 21 U.S.C. §§ 841, 846.
Loaiza pleaded guilty to a superseding indictment without a plea agreement and the parties agreed to certain PSR adjustments, producing an offense level 37 and criminal-history I (Guidelines range 210–262 months).
The district court adopted the PSR, denied Loaiza’s variance motion after considering § 3553(a) factors, and imposed a 210-month sentence (bottom of the Guidelines range) plus five years supervised release.
On appeal Loaiza argued the within-Guidelines sentence was substantively unreasonable because the district court failed to give proper weight to his § 3553(a) arguments (nonviolent offense, personal history, disparities, lack of treatment due to immigration status).
The Eighth Circuit affirmed, finding the district court adequately considered § 3553(a) factors and did not abuse its discretion in weighing them.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the within-Guidelines sentence was substantively unreasonable	Loaiza: district court failed to give proper weight to mitigating § 3553(a) factors (nonviolent nature, personal history, sentencing disparities, lack of access to treatment)	Government: sentence is appropriate; court should treat Loaiza like other defendants and impose Guidelines sentence	Affirmed — no abuse of discretion; court considered § 3553(a) factors and permissibly weighed them

United States v. Leonard, 785 F.3d 303 (8th Cir. 2015) (standard: abuse-of-discretion review for substantive reasonableness)
United States v. Luleff, 574 F.3d 566 (8th Cir. 2009) (abuse-of-discretion framing)
United States v. Watson, 480 F.3d 1175 (8th Cir. 2007) (reversal appropriate if court omits a significant factor, gives weight to improper factor, or commits clear judgment error)
United States v. Battiest, 553 F.3d 1132 (8th Cir. 2009) (review entire sentencing record to determine whether relevant factors were considered)
United States v. Beasley, 688 F.3d 523 (8th Cir. 2012) (presumption of reasonableness for within-Guidelines sentences)
United States v. San-Miguel, 634 F.3d 471 (8th Cir. 2011) (district court has wide latitude in weighing § 3553(a) factors)
United States v. Bridges, 569 F.3d 374 (8th Cir. 2009) (same; deference to district court’s balancing)
United States v. Meza-Lopez, 808 F.3d 743 (8th Cir. 2015) (reliance on one factor over another is not alone reversible)
United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (reversal for substantive unreasonableness is unusual)
United States v. Gardellini, 545 F.3d 1089 (D.C. Cir. 2008) (same principle on rarity of reversal for substantive reasonableness)