United States v. Naranjo
102 F.4th 280
5th Cir.2024Background
- Rudy Naranjo was convicted in 2007 of multiple drug conspiracy offenses involving crack and powder cocaine, as well as use of a firearm in furtherance of a drug trafficking crime.
- Naranjo received concurrent 360-month sentences for the drug offenses and a consecutive 120-month sentence for the firearm offense.
- He previously filed several unsuccessful motions for sentence reduction under the Fair Sentencing Act and Section 404 of the First Step Act, all denied on grounds of ineligibility and on the merits.
- Naranjo's core argument relied on recent Supreme Court guidance that courts may consider intervening legal changes during sentence reductions under the First Step Act.
- He filed a second Section 404 motion in 2022, which was dismissed for lack of jurisdiction and, in the alternative, on the merits—the district court found input from new law wouldn't change his guideline range or sentence.
Issues
| Issue | Naranjo's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether Section 404(c) is jurisdictional or claim-processing | Section 404(c) is not jurisdictional; court can hear multiple motions | Section 404(c) bars second motions after a complete merits review | Not jurisdictional, but a mandatory claim-processing rule |
| Whether Naranjo's second Section 404 motion could proceed | Entitled to resentencing considering new caselaw (Concepcion) | Second motion barred after merits review of the first motion | District court correctly enforced bar on second motion |
| Whether recalculation of sentence was required | Crack conviction and change in law justify Guidelines recalculation | Sentence would be the same even under new law; bar applies | No resentencing required; bar enforced |
| Whether merits of § 3553(a) factors or § 924(c) claim should be reviewed | Court failed to consider full slate of arguments | Not permissible under First Step Act or after previous review | Relief unavailable under First Step Act |
Key Cases Cited
- Dorsey v. United States, 567 U.S. 260 (2012) (interprets retroactivity of Fair Sentencing Act and First Step Act applicability)
- Fort Bend Cnty. v. Davis, 139 S. Ct. 1843 (2019) (explains distinction between jurisdictional and claim-processing rules)
- Arbaugh v. Y&H Corp., 546 U.S. 500 (2006) (clear statement required for jurisdictional bars)
- Henderson v. Shinseki, 562 U.S. 428 (2011) (clarifies when claim-processing rules are not jurisdictional)
- Eberhart v. United States, 546 U.S. 12 (2005) (mandatory but waivable claim-processing rules)