United States v. Medina, 2013 U.S. App. LEXIS 17993

Between 2001 and 2009 Medina allegedly fronted kilogram quantities of cocaine to co-defendant Mario Melendez; surveillance confirmed a 1‑kg delivery in August 2008.
Medina was arrested in December 2009; agents found 9.5 kg of cocaine, packaging materials, $124,124 cash, and ~$51,890 in jewelry in his garage.
Medina pleaded guilty to conspiracy to distribute cocaine and possession with intent to distribute; he initially admitted owning cocaine and the government's factual proffer described extensive multi‑year supply.
Melendez gave two post‑arrest statements attributing between ~52.5 and ~70.5 kg to Medina over the course of the relationship; the PSR adopted a 67.5 kg calculation, defendant objected.
At sentencing the district court credited Melendez’s statements as against interest but adopted a conservative finding of 15–50 kg total drug quantity, producing a Guidelines range and a 190‑month sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of proof for drug‑quantity at sentencing	Medina: judge must find drug quantity beyond a reasonable doubt	Government: preponderance applies under Sentencing Guidelines	Court: preponderance of the evidence is the correct standard (Seventh Circuit precedent)
Reliability of co‑defendant’s out‑of‑court statements used to increase quantity	Medina: Melendez’s statements are self‑serving, possibly motivated by avoiding cartel reprisal, and unreliable; court couldn’t assess credibility firsthand	Government: statements were against interest and corroborated by seized drugs, cash, and jewelry	Court: district court did not clearly err; statements were sufficiently against interest and corroborated; 15–50 kg finding supported by preponderance

United States v. Johnson, 342 F.3d 731 (7th Cir.) (preponderance standard for sentencing findings)
United States v. Reuter, 463 F.3d 792 (7th Cir.) (same)
United States v. Hankton, 432 F.3d 779 (7th Cir.) (clear‑error standard for sentencing factfinding)
United States v. Breland, 356 F.3d 787 (7th Cir.) (preponderance defined for drug‑quantity attribution)
United States v. Longstreet, 567 F.3d 911 (7th Cir.) (sentencing information must have sufficient indicia of reliability)
United States v. Acosta, 584 F.3d 574 (7th Cir.) (district courts may reasonably estimate attributable drug quantity)
United States v. Jarrett, 133 F.3d 519 (7th Cir.) (rejecting unsupported "nebulous eyeballing" at sentencing)