United States v. Lucio, 985 F.3d 482

Lucio pleaded guilty to conspiracy to distribute methamphetamine after controlled buys (~0.083 kg total) and a search of his home (meth, cocaine, marijuana, firearms, ~$16K cash).
Law enforcement found a text exchange referencing “food” and “24 or 25” to be picked up at McDonald’s; an agent and the PSR interpreted this as 24 kg of meth.
Co-defendant/co-conspirator Murrell Wilson told officers Lucio dealt meth in kilogram quantities, received multiple large shipments (including 10-kg and 1-kg deliveries), and stored ~48 kg in a relative’s shed.
The PSR attributed a converted drug-weight total of 109,294.25 kg to Lucio, including 24 kg from the texts and 2.83 kg derived by converting $18,368 in seized cash using Lucio’s quoted $6,500/kg price.
The district court adopted the PSR findings, overruled Lucio’s objections, but granted a downward variance by treating all meth as “plain” (not higher-purity “ice”), yielding a sentence of 324 months.
On appeal Lucio challenged only the district court’s drug-quantity findings (the 24-kg text transaction and the cash-to-meth conversion); the Fifth Circuit affirmed, deferring to the district court’s factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the text messages supported attributing 24 kg of meth to Lucio	United States: Texts used coded terms; agent interpretation + Wilson’s statements and Lucio’s kilo price make 24 kg a plausible inference	Lucio: Texts are cryptic; "food" could be other drugs or non-drug items; unit unspecified; post-search meth quantity small	Court: Affirmed—no clear error; PSR + co-conspirator statements + agent expertise make 24 kg attribution plausible
Whether $18,368 in seized cash could be converted into meth quantity	United States: Lucio was a meth kilo dealer; cash likely proceeds of meth sales and converts to ~2.83 kg at his quoted price	Lucio: Cash could derive from cocaine/marijuana sales or other sources; not necessarily meth proceeds	Court: Affirmed—no clear error; record supports inference cash came from meth trafficking and conversion was reasonable

United States v. Arayatanon, 980 F.3d 444 (5th Cir.) (standard: drug-quantity factual findings reviewed for clear error)
United States v. Betancourt, 422 F.3d 240 (5th Cir.) (permitting reasonable extrapolation to estimate drug quantity)
United States v. Koss, 812 F.3d 460 (5th Cir.) (drug-quantity finding must be plausible in light of the whole record)
United States v. Kearby, 943 F.3d 969 (5th Cir.) (deference to district court; plausibility standard)
United States v. Zuniga, 720 F.3d 587 (5th Cir.) (PSR must bear sufficient indicia of reliability)
United States v. Gaytan, 74 F.3d 545 (5th Cir.) (uncorroborated hearsay can suffice where other parts are corroborated)
United States v. Alford, 142 F.3d 825 (5th Cir.) (district court may rely on imprecise coconspirator estimates)
United States v. Gentry, 941 F.3d 767 (5th Cir.) (patently incorrect PSR statements cannot form basis for drug-quantity estimate)
United States v. Haines, 803 F.3d 713 (5th Cir.) (district court may convert seized cash into equivalent drug quantity)