United States v. Luis Fernando Mancillas Medina
656 F. App'x 975
| 11th Cir. | 2016Background
- Medina pleaded guilty to conspiracy to distribute ≥5 kg of cocaine and money-laundering/transaction offenses; sentenced to 210 months (top of Guidelines range).
- He worked from ~2001 for leader Hugo Ramirez, transporting hundreds of kilograms of narcotics and handling millions in drug proceeds.
- Co-conspirators (arrested in the same investigation) were found with multiple firearms seized in close proximity to drugs and proceeds.
- The PSR applied a two-level U.S.S.G. § 2D1.1(b)(1) dangerous-weapon enhancement based on co-conspirator firearm possession and denied a minor-role adjustment under U.S.S.G. § 3B1.2.
- District court denied Medina’s objections and imposed concurrent 210-month terms; Medina did not object to the sentence below and appealed.
Issues
| Issue | Plaintiff's Argument (Medina) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Dangerous-weapons enhancement | Enhancement improper: Medina never possessed or transported guns and could not reasonably foresee them | Enhancement proper: co-conspirator possession was in furtherance of conspiracy and reasonably foreseeable given large-scale, valuable drug trafficking | Affirmed: enhancement valid; possession by co-conspirators proximate to drugs/proceeds made possession foreseeable and in furtherance |
| Minor-role reduction | Medina was a courier and thus entitled to a two-level minor-role reduction | Medina was more than a minor participant: worked closely with leader Ramirez, moved large quantities and large sums | Affirmed: denial proper—courier label not dispositive; facts show significant role |
| Substantive reasonableness of sentence | Sentence substantively unreasonable and disparate compared to co-defendant Hernandez | Sentence reasonable: within Guidelines, below statutory max; differences in culpability explain disparity | Affirmed: sentence not substantively unreasonable; disparity with Hernandez not unwarranted or insufficient to overcome § 3553(a) factors |
Key Cases Cited
- United States v. Smith, 480 F.3d 1277 (11th Cir.) (standard for de novo review of Guidelines interpretation and clear-error review of facts)
- United States v. Pham, 463 F.3d 1239 (11th Cir.) (co-conspirator firearm possession can support enhancement if foreseeable and in furtherance)
- United States v. Stallings, 463 F.3d 1218 (11th Cir.) (government must show nexus beyond mere possession for weapons enhancement)
- United States v. Fields, 408 F.3d 1356 (11th Cir.) (firearms found where drugs were sold support inference they were in furtherance)
- United States v. Rodriguez De Varon, 175 F.3d 930 (11th Cir.) (standard and burden for role-in-offense adjustments)
- United States v. Alvarez-Coria, 447 F.3d 1340 (11th Cir.) (procedures for comparing defendant’s role to relevant conduct and others)
- Gall v. United States, 552 U.S. 38 (2007) (reasonableness review framework for sentencing)
- United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir.) (substantive-reasonableness standard; rare to find abuse of discretion)