United States v. Medina-Villegas
700 F.3d 580
| 1st Cir. | 2012Background
- Indictment of Medina-Villegas and codefendants for armored-car robbery and guard killed; counts 8 and 9 concern firearms during crime of violence and death resulting, respectively.
- Initial district court sentence included life imprisonment without release on count 8 and 30-year term on count 9.
- On appeal, we vacated count 8 sentence to permit allocution and remanded.
- At resentencing, the district court conducted allocution and reinstated the original sentence (life on count 8).
- Appellant challenged procedural and substantive reasonableness and raised a belated double jeopardy claim during remand.
- We affirmed after reviewing procedural controls, substantive reasonableness within the guideline range, and law-of-the-case constraints on the double jeopardy issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court’s failure to explain 3553(c) reasons is plain error | Medina-Villegas argues insufficient explanation mandating reversal | Medina-Villegas contends inadequate explanation affected fairness | No plain error; insufficient showing of likely different sentence on remand |
| Whether the within-GSR life sentence is substantively reasonable | Life sentence is excessive given remand context | Sentence within GSR given grave offense and leading role | Within-GSR; not substantively unreasonable under standard |
| Whether the double jeopardy claim was preserved or allowed under law of the case | Claim belated and not preserved on first appeal | Law of the case bars reexamination; no change in controlling law | Law of the case bars reconsideration; affirmed without new double jeopardy review |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (U.S. 2007) (two-stage review of sentence; plain error standard)
- United States v. Martin, 520 F.3d 87 (1st Cir. 2008) (guidelines-based procedural/substantive review framework)
- United States v. Clogston, 662 F.3d 588 (1st Cir. 2011) (procedural/substantive reasonableness bifurcated review)
- United States v. Mangual-Garcia, 505 F.3d 1 (1st Cir. 2007) (plain error review when error undisclosed at sentencing)
- United States v. Guzmán, 419 F.3d 27 (1st Cir. 2005) (3553 factors and explanation requirements)
- United States v. Morales-Machuca, 546 F.3d 13 (1st Cir. 2008) (substantive reasonableness within range; demanding standard)
- Catalán-Roman, 585 F.3d 453 (1st Cir. 2009) (earlier ruling on double jeopardy and allocation of relief)