United States v. Mata
624 F.3d 170
| 5th Cir. | 2010Background
- Mata pleaded guilty to transporting an undocumented alien for financial gain under 8 U.S.C. § 1324; Guerrero-Cruz was hidden under a stroller in Mata's vehicle during the stop.
- Base offense level was 12; the probation officer added a 6-level reckless-endangerment enhancement under § 2L1.1(b)(6) and a 2-level enhancement under § 3B1.4 for use of a minor, with a 2-level reduction for acceptance of responsibility, yielding a final offense level of 18.
- District court overruled Mata's objections, applied the enhancements, and sentenced Mata to 45 months' imprisonment and a 3-year supervised release term.
- One supervised-release condition required Mata to participate in a mental-health program as deemed necessary by the Probation Department; Mata did not object below.
- Mata challenged the § 2L1.1(b)(6) and § 3B1.4 enhancements on appeal and asserted plain error in delegating mental-health determinations to the Probation Department.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 2L1.1(b)(6) reckless endangerment applies | Mata disputes application of the enhancement. | The government argues the facts support the enhancement. | Affirmed; findings plausibly support the enhancement. |
| Whether § 3B1.4 use of a minor applies | Mata contends no use of a minor to avoid detection. | The government shows Mata used minors to mislead and deter detection. | Affirmed; district court properly found use of minors to avoid detection. |
| Whether the district court impermissibly delegated mental-health supervision condition to the Probation Department | Mata argues delegation violates judicial authority. | The government relies on controlling precedent allowing such delegation. | Affirmed; delegation not plain error in light of controlling precedent. |
Key Cases Cited
- United States v. Williams, 610 F.3d 271 (5th Cir. 2010) (guideline interpretation framework and deference to factual findings)
- United States v. Molina, 469 F.3d 408 (5th Cir. 2006) (use of a minor as a decoy under § 3B1.4; circumstantial evidence allowed)
- United States v. Solis-Garcia, 420 F.3d 511 (5th Cir. 2005) (limits on the reach of § 2L1.1(b)(6) and Bailor factors)
- United States v. Zuniga-Amezquita, 468 F.3d 886 (5th Cir. 2006) (five-factor framework for reckless-endangerment enhancement)
- United States v. Rodriguez-Mesa, 443 F.3d 397 (5th Cir. 2006) (application of indices for danger in.endangerment context)
- United States v. Preciado, 506 F.3d 808 (9th Cir. 2007) (circumstantial evidence supporting § 3B1.4 when minor used to avoid detection)