United States v. Laureano-Perez, 892 F.3d 50

On May 5, 2016, Puerto Rico police observed Jesús Manuel Laureano-Pérez flee; officers saw him remove a firearm from a fanny pack, discard it over a fence, and recovered the weapon, high-capacity magazines, and cell phones.
Laureano was on supervised release for a 2013 federal conviction for possession of cocaine with intent to distribute when the fanny-pack incident occurred.
He pled guilty to two counts: possession of a firearm by a convicted felon (18 U.S.C. § 922(g)(1)) and unlawful possession of a machine gun (18 U.S.C. § 922(o)).
The Sentencing Guidelines range for the firearm counts was 37–46 months; the district court varied upward and imposed concurrent 60-month sentences on each count.
The district court also ordered a term of supervised release with periodic random drug testing; Laureano had previously been subject to random testing and refused to provide a urine sample at his arrest.
Laureano appealed, arguing (1) the upward variance was procedurally/substantively unreasonable because the district court relied on community-wide concerns, and (2) the drug-testing condition was improper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the upward variance to 60 months was reasonable	Government: variance justified by offense seriousness, deterrence, public-safety concerns	Laureano: district court improperly relied on community-wide violence and failed to explain or anchor variance in his individual circumstances	Affirmed — court found the judge considered defendant-specific factors (age, education, work history, offense conduct) and recent First Circuit precedent permits such variances
Whether imposing random drug testing on supervised release was proper	Government: testing relates to defendant's history as a drug dealer, prior refusal of a urine sample, and supervised-release objectives	Laureano: (forfeited by failure to object at sentencing) argued testing was improper	Affirmed — objection forfeited; testing condition reasonably related to defendant’s history and 18 U.S.C. § 3553(a) objectives

Gall v. United States, 552 U.S. 38 (2007) (district courts have broad discretion to vary from Guidelines)
United States v. Paulino-Guzman, 807 F.3d 447 (1st Cir. 2015) (upholding variance where court considered offender characteristics and offense seriousness)
United States v. Fuentes-Echevarria, 856 F.3d 22 (1st Cir. 2017) (affirming upward variance on similar facts)
United States v. Quiñones-Otero, 869 F.3d 49 (1st Cir. 2017) (explaining when court need not elaborate on imposed conditions if reasoning is apparent)
United States v. Colón de Jesús, 831 F.3d 39 (1st Cir. 2016) (supervised-release conditions must be reasonably related to rehabilitative and public-safety goals)
United States v. Garrasteguy, 559 F.3d 34 (1st Cir. 2009) (failure to object at sentencing forfeits appellate review except for plain error)