United States v. Leobardo Barraza, 982 F.3d 1106

In 1998, Leobardo Barraza (age 16) and an adult lured Maria Eloiza and her five‑year‑old son; Barraza and an accomplice raped and murdered both. Barraza was later charged and convicted of kidnapping resulting in death.
Barraza received a statutorily mandated life sentence; after Miller v. Alabama, the district court vacated the sentence and ordered resentencing.
Pre‑resentencing, the district court initially found Barraza incompetent (Oct. 2018) and committed him for competency restoration.
A later Bureau of Prisons evaluation by Dr. Allyson Wood concluded Barraza was competent; the district court adopted that opinion and found Barraza competent to proceed.
At resentencing the court calculated an advisory Guidelines range of life (U.S.S.G. § 2A1.1), but imposed a downward variance to 50 years after applying the § 3553(a) factors and considering Barraza’s youth under Miller.
Barraza appealed, arguing (1) the competency finding was clearly erroneous, (2) application of § 2A1.1 to a juvenile was plain error under Miller, and (3) the 50‑year sentence was substantively unreasonable. The Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency to proceed to resentencing	Barraza: district clearly erred; nothing materially changed since earlier incompetency finding and Dr. Wood’s report is insufficient	Court relied on Dr. Wood’s recent, in‑person evaluation, institutional record, and observed behavior showing capacity to assist counsel	Affirmed — no clear error in finding Barraza competent
Use of U.S.S.G. § 2A1.1 (Guidelines life range) for juvenile offender	Barraza: plain error — §2A1.1 (life) ignores Miller’s youth‑based considerations; Court improperly used it as lodestar	Guidelines are advisory; court must calculate them as the starting point (Gall) and then apply §3553(a) informed by Miller; court did so here	Affirmed — no plain error in calculating life range under §2A1.1 and then varying downward after considering Miller
Substantive reasonableness of 50‑year sentence	Barraza: sentence substantively unreasonable; court overemphasized premeditation (not found by jury) and imposed a harsher term than in comparable juvenile resentencings	Sentence is a below‑Guidelines variance; district court engaged in individualized §3553(a) analysis informed by youth and case facts	Affirmed — 50 years is substantively reasonable (presumption favors within/below Guidelines)

Miller v. Alabama, 567 U.S. 460 (juveniles: categorical ban on mandatory life without parole; require individualized consideration of youth)
Gall v. United States, 552 U.S. 38 (district courts should calculate Guidelines as starting point; appellate review for abuse of discretion)
Alleyne v. United States, 570 U.S. 99 (factfinding that increases mandatory minimum must be submitted to jury)
United States v. Jefferson, 816 F.3d 1016 (8th Cir.: Miller requires §3553(a) analysis informed by youth in federal sentencing)
United States v. Contreras, 816 F.3d 502 (8th Cir.: district court may rely on Bureau of Prisons psychiatrist in competency determinations)
United States v. Feemster, 572 F.3d 455 (8th Cir.: abuse‑of‑discretion standard for sentencing review)
United States v. Canania, 532 F.3d 764 (8th Cir.: within or below Guidelines is presumptively reasonable)