United States v. Misael Rodriguez-Sanchez, 669 F. App'x 271

Defendant Misael Jose Rodriguez-Sanchez pleaded guilty to conspiracy to possess with intent to distribute methamphetamine and was sentenced to the statutory minimum 10 years imprisonment and three years supervised release.
He sought a two-level safety-valve reduction under U.S.S.G. § 5C1.2, arguing he truthfully provided the government information shortly before sentencing via a letter.
He also challenged the district court’s determination of drug quantity (accountability for 1.3 kg actual methamphetamine) and denial of a mitigating role adjustment under U.S.S.G. § 3B1.2.
The district court denied safety-valve relief because the letter was disclosed late and the government had insufficient time to verify its contents; the court did not make detailed factual findings about the letter’s truthfulness on the record.
On appeal, Rodriguez-Sanchez raised (1) that the district court failed to find the letter truthful and (2) that the court conflated safety-valve requirements with substantial-assistance standards; review was for plain error because these arguments were not preserved.
The court held that Rodriguez-Sanchez failed to show plain error on the safety-valve point and that any other sentencing errors were harmless because he received the statutory minimum sentence (absent safety-valve or 5K1.1 relief the court lacked authority to go below the statutory minimum).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred in denying safety-valve relief under § 5C1.2	Rodriguez-Sanchez: district court failed to make factual findings about truthfulness and conflated safety-valve with § 5K1.1 standards	Government: letter was disclosed too late for verification; defendant failed to meet his burden to debrief truthfully	No plain error; district court implicitly found letter untimely/unverifiable and did not conflate standards
Drug-quantity accountability (1.3 kg actual methamphetamine)	Rodriguez-Sanchez: challenges district court’s finding of 1.3 kg accountability	Government: quantity finding supported	Court did not need to reach merits because any Guidelines error was harmless given statutory minimum sentence
Denial of mitigating-role adjustment under § 3B1.2	Rodriguez-Sanchez: should have received lesser-role reduction	Government: denial supported by record	Not considered on merits because any error harmless due to statutory minimum sentence
Whether any Guidelines calculation errors were harmless	Rodriguez-Sanchez: errors could affect sentence	Government: errors harmless because statutory minimum prevented a lower sentence absent safety-valve or substantial-assistance reduction	Held harmless; appellate court need not address remaining issues because sentence was statutory minimum and court lacked authority to go lower without the exceptions

Puckett v. United States, 556 U.S. 129 (2009) (plain-error test and relief discretionary when errors affect substantial rights)
Mondragon-Santiago v. United States, 564 F.3d 357 (5th Cir. 2009) (preservation and plain-error review in sentencing contexts)
Flanagan v. United States, 80 F.3d 143 (5th Cir. 1996) (defendant bears burden to truthfully debrief for safety-valve relief)
Montes v. United States, 602 F.3d 381 (5th Cir. 2010) (statutory minimum cannot be reduced absent safety-valve or substantial-assistance exception)
Sandle v. United States, 123 F.3d 809 (5th Cir. 1997) (errors in Guidelines range are harmless where sentence is statutory minimum)