United States v. Marcelino Sanchez-Mata
663 F. App'x 863
| 11th Cir. | 2016Background
- Sanchez-Mata pleaded guilty to reentry of a deported alien under 8 U.S.C. §1326(a),(b)(2).
- He was sentenced to 54 months, below the advisory range of 57–71 months.
- The district court varied downward by 3 months for time in ICE custody, but denied a further variance based on criminal history.
- Sanchez argued the criminal history category overstated his history and that reentry was for family reunification.
- The appellate court affirmed the sentence as substantively reasonable and within the district court’s discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion by denying further variance for criminal history | Sanchez contends CHC overstated history and warrants more variance | Government argues CHC properly calculated and supported</s> | No abuse; court affirmed discretion to deny further variance. |
| Whether the ICE-time variance was proper | Sanchez seeks additional variance including ICE custody time | Court appropriately applied a 3-month ICE variance | Court upheld 3-month ICE variance. |
| Whether the overall sentence is substantively reasonable | Sentence is too harsh given mitigating factors | Factors weighed support the chosen sentence | Sentence not substantively unreasonable; affirmed. |
Key Cases Cited
- United States v. Cubero, 754 F.3d 888 (11th Cir. 2014) (two-step reasonableness review: procedural then substantive)
- United States v. Alvarado, 808 F.3d 474 (11th Cir. 2015) (deference to district court in balancing §3553(a) factors)
- United States v. Pugh, 515 F.3d 1179 (11th Cir. 2008) (abuse of discretion standard for reasonable sentence ranges)
- United States v. Dougherty, 754 F.3d 1353 (11th Cir. 2014) (defer to district court on weighing §3553(a) factors)