United States v. Juan Manzano-Huerta, 809 F.3d 440

Manzano owned and ran Manzano Grain Bin Services, employing crews he directed, providing equipment, lodging, and pay; many workers were undocumented immigrants.
After an HSI agent interviewed Manzano in Aug. 2013, he pleaded guilty to harboring and conspiring to harbor illegal aliens under 8 U.S.C. § 1324.
The plea agreement included a factual stipulation that Manzano “believed he could pay the workers and crew chiefs as independent contractors and did not withhold taxes.”
At sentencing, the Government sought a two-level USSG § 3C1.1 obstruction enhancement, arguing Manzano falsely told the agent that a crew chief (Perez) was a subcontractor and then encouraged Perez to corroborate that claim on a recorded call.
The district court credited Perez’s version of the call, applied the obstruction enhancement, denied a three-level USSG § 3E1.1 acceptance adjustment, and sentenced Manzano to 33 months.
Manzano appealed, arguing (1) the Government breached the plea agreement by treating his statements as lies contrary to the stipulation, and (2) the obstruction enhancement and denial of acceptance were erroneous.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Government breached the plea agreement by arguing Manzano lied about classifying workers as subcontractors	Manzano: The stipulation shows he believed workers were subcontractors, so Government’s characterization of his statements as lies contradicts and breaches the plea agreement	Government: The stipulation only records Manzano’s belief that paying as subcontractors was proper; obstruction theory was based on his shifting blame to Perez, not mere classification	No breach: Court reads stipulation narrowly and finds Government’s obstruction theory consistent with other stipulations showing Manzano acted as an employer
Whether § 3C1.1 enhancement and denial of § 3E1.1 credit were erroneous	Manzano: His statements reflected his belief and did not obstruct; transcripts supporting corroboration are inconsistent; his statements did not impede the investigation	Government: Manzano lied to the agent and encouraged Perez to corroborate; false statements forced extra investigative steps; obstructive conduct negates acceptance credit	Affirmed: Credibility findings not clearly erroneous; false statements impeded investigation; obstruction supports denial of acceptance credit except in extraordinary cases

Noriega v. United States, 760 F.3d 908 (8th Cir. 2014) (plea agreements interpreted by contract principles)
Margalli-Olvera v. INS, 43 F.3d 345 (8th Cir. 1994) (plea agreements are contractual and interpreted accordingly)
Louismet v. Bielema, 457 N.W.2d 10 (Iowa Ct. App. 1990) (factors indicating employer relationship: furnishing workplace, tools, and equipment)
Yarrington v. United States, 634 F.3d 440 (8th Cir. 2011) (predicate facts for obstruction enhancement reviewed for clear error)
Montes-Medina v. United States, 570 F.3d 1052 (8th Cir. 2009) (standards for obstruction findings)
Williams v. United States, 288 F.3d 1079 (8th Cir. 2002) (false statements to law enforcement are obstructive only if they hinder investigation)
Finck v. United States, 407 F.3d 908 (8th Cir. 2005) (obstruction enhancement appropriate where false statements delayed investigation and caused extra resource expenditure)
Walker v. United States, 688 F.3d 416 (8th Cir. 2012) (district court’s acceptance-of-responsibility determinations reviewed for clear error)
Honken v. United States, 184 F.3d 961 (8th Cir. 1999) (obstructive conduct ordinarily precludes acceptance-of-responsibility reduction)