United States v. Naranjo
20-50257
| 5th Cir. | Jun 25, 2021Background
- Rudy Naranjo was convicted of cocaine-base drug offenses and related firearm offenses and sentenced principally to 480 months’ imprisonment.
- Naranjo moved for a sentence reduction under § 404 of the First Step Act (and earlier sought relief under 18 U.S.C. § 3582(c)(2)); he also filed a purported Rule 60(b) motion.
- The district court construed and denied the first § 404 filing as unauthorized, later considered a second § 404 motion on the merits, and denied relief under § 404.
- Naranjo appealed only the order denying the second § 404 motion; he did not appeal the district court’s orders on the first § 404 filing, the Rule 60(b) motion, or § 3582(c)(2) claims.
- The court below declined to order a new PSR, declined to reduce any sentence (including the firearms sentence), noted the Guidelines range remained 360 months to life, and refused to disturb the career-offender designation.
- The Fifth Circuit affirmed the denial of the second § 404 motion and held it lacked jurisdiction to review the other orders or the § 3582(c)(2) claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying § 404 relief without ordering a revised PSR or conducting a full substantive resentencing | Naranjo: court failed to conduct a complete substantive review and should have ordered a revised PSR | U.S.: First Step Act gives limited authority, not a plenary resentencing; court properly exercised discretion | No abuse of discretion; court need not order a new PSR and properly declined relief |
| Whether § 404 authorizes reducing the firearm sentence | Naranjo: sought relief to reduce firearm sentence | U.S.: § 404 covers certain drug offenses only; firearms not within statute | Denial proper; § 404 does not permit reducing firearm sentence |
| Whether the court erred by failing to apply the 2018 Sentencing Guidelines when evaluating § 404 relief | Naranjo: court should have applied 2018 Guidelines | U.S.: even if not applied, Guidelines range is unchanged; any error harmless | No reversible error; any failure to apply 2018 Guidelines was harmless because range remained 360 months–life |
| Whether the court should have vacated the career‑offender designation | Naranjo: career‑offender designation should be reversed | U.S.: challenge is foreclosed under controlling precedent | Rejected; claim foreclosed (Hegwood) |
| Whether this Court may review denial of first § 404 motion, the Rule 60(b) motion, or § 3582(c)(2) relief | Naranjo: sought review of those orders | U.S.: notice of appeal identified only the second § 404 denial; appellate jurisdiction is limited | No jurisdiction to review the first § 404 order, the Rule 60(b) order, or § 3582(c)(2) claims |
Key Cases Cited
- United States v. Hegwood, 934 F.3d 414 (5th Cir. 2019) (First Step Act §404 provides limited relief; not a plenary resentencing)
- United States v. Batiste, 980 F.3d 466 (5th Cir. 2020) (standard for abuse of discretion review of §404 decisions)
- United States v. Jackson, 945 F.3d 315 (5th Cir. 2019) (statutory interpretation reviewed de novo)
- United States v. Stewart, 964 F.3d 433 (5th Cir. 2020) (§404 motions cannot exploit unrelated changes in law)
- United States v. Clayton, 613 F.3d 592 (5th Cir. 2010) (appellate jurisdiction limited to matters identified in notice of appeal)
- United States v. Coscarelli, 149 F.3d 342 (5th Cir. 1998) (en banc) (same jurisdictional limitation principle)
- United States v. Garcia, 655 F.3d 426 (5th Cir. 2011) (applying harmless‑error analysis in sentence-modification review)