United States v. Juan Saucedo
670 F. App'x 351
| 5th Cir. | 2016Background
- Juan Saucedo, federal prisoner, moved under 18 U.S.C. § 3582(c)(2) for a sentence reduction based on Amendment 782 to the Sentencing Guidelines.
- Saucedo argued the district court never accepted his Rule 11(c)(1)(C) plea agreement because of a transcription error and thus he remained eligible for a guidelines-based reduction.
- The plea agreement stipulated an upward departure to a 180-month term despite a calculated guidelines range of 120–135 months.
- The district court sentenced Saucedo to 180 months pursuant to the plea agreement; the record shows the court accepted and applied the stipulated sentence.
- The district court denied § 3582(c)(2) relief; Saucedo appealed, arguing eligibility and also raising Rule 11 and interpreter claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Saucedo was eligible for § 3582(c)(2) relief based on Amendment 782 | Saucedo: plea not accepted (transcription error), so sentence remains tied to guidelines; eligible for reduction | Government: sentence was imposed per Rule 11(c)(1)(C) stipulation (180 months), not based on guideline range; Amendment 782 does not lower his applicable range | Court: Sentence derived from plea stipulation, not the guidelines; Amendment 782 does not lower his applicable range; § 3582(c)(2) relief denied |
| Whether the district court violated Rule 11 or failed to appoint an interpreter | Saucedo: procedural defects at plea/sentencing (Rule 11 error; no interpreter) | Government: such challenges are collateral to § 3582(c)(2) motions and not cognizable here | Court: These challenges are not cognizable in a § 3582(c)(2) motion; claims rejected |
Key Cases Cited
- United States v. Benitez, 822 F.3d 807 (5th Cir.) (distinguishing Rule 11(c)(1)(C) stipulated sentences from guidelines-based sentences for § 3582(c)(2) eligibility)
- Freeman v. United States, 564 U.S. 522 (2011) (discussing nature of Rule 11(c)(1)(C) plea agreements)
- United States v. Henderson, 636 F.3d 713 (5th Cir.) (applying § 3582(c)(2) eligibility principles)
- United States v. Evans, 587 F.3d 667 (5th Cir.) (explaining non-cognizability of collateral challenges in § 3582(c)(2) motions)
Affirmed; Saucedo's motion denied.