United States v. Juan Ramos-Delgado
763 F.3d 398
| 5th Cir. | 2014Background
- Ramos-Delgado drove a truck with several illegal aliens; Salgado-Flores acted as a coyote.
- They attempted to elude border patrol by making a sharp left across median, crashing through a fence and into a tree.
- Two aliens in the truck bed were seriously injured; one, Carcamo-Bautista, suffered severe brain injuries and later died.
- Probation initially recommended a 6-level enhancement under § 2L1.1(b)(7)(C) for life-threatening injuries; a Honduran consulate email indicated Carcamo-Bautista’s death, prompting a ten-level enhancement under § 2L1.1(b)(7)(D).
- Defense objected to the 10-level enhancement, arguing insufficient proof that Carcamo-Bautista died from the crash and that death was ascertainable.
- The district court concluded Carcamo-Bautista died from the injuries and applied the ten-level enhancement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 2L1.1(b)(7) requires but-for causation | Ramos-Delgado/Salgado-Flores contend there is no causation evidence without death as a proven outcome. | Ramos-Delgado/Salgado-Flores argue there is no required causal link to apply the enhancement absent proven death causation. | Ten-level enhancement permitted without proximate causation; but-for causation established. |
Key Cases Cited
- United States v. Cisneros-Gutierrez, 517 F.3d 751 (5th Cir. 2008) (guidelines facts review and standard of review for sentencing)
- United States v. Caldwell, 448 F.3d 287 (5th Cir. 2006) (reasonable inferences as fact-findings in applying enhancements)
- United States v. Ekanem, 555 F.3d 172 (5th Cir. 2009) (standard of review for factual findings; plausibility in record)
- United States v. Juarez, 626 F.3d 246 (5th Cir. 2010) (preponderance burden for sentencing enhancements)
- Burrage v. United States, 134 S. Ct. 881 (U.S. 2014) (but-for causation framework in causation discussions)
- Paroline v. United States, 134 S. Ct. 1710 (U.S. 2014) (causation discussion in restitution/causation context)
- University of Texas Southwestern Med. Ctr. v. Nassar, 133 S. Ct. 2517 (U.S. 2013) (causation concepts and scientific/causal reasoning guidance)