United States v. Pedro Meza, 708 F. App'x 190

Defendant Pedro Jose Meza pleaded guilty to producing child pornography (18 U.S.C. § 2251(a)) and distributing child pornography (18 U.S.C. § 2252(a)(2)).
District court imposed a 50-year (600-month) sentence, the statutory cap given consecutive statutory maxima (30 years + 20 years).
Meza challenged two guideline rulings on appeal: (1) application of U.S.S.G. § 2G2.2(b)(6) for using a "computer or an interactive computer service" (he had used a cell phone), and (2) whether two juvenile adjudications counted as "sex offense conviction[s]" under U.S.S.G. § 4B1.5(a) (affecting the § 4B1.5(b)(1) five-level increase for a pattern of prohibited sexual conduct).
If both challenges succeeded, the advisory guidelines range would have shifted from "life" to "360 months to life," though the statutory cap would remain 600 months; if one failed, the guideline range would be unchanged.
The district court emphasized Meza's extensive history of sexual abuse, resistance to treatment, and danger to the public, stating it would impose the same long sentence even if the guideline calculation were different.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether use of a cell phone qualifies as using "a computer or an interactive computer service" under U.S.S.G. § 2G2.2(b)(6)	Meza: cell phone use should not trigger the § 2G2.2(b)(6) enhancement	Government: cell phone use to produce/store/distribute images qualifies as a computer/interactive service for the enhancement	Court did not decide the merits; any error would be harmless because the court would have imposed the same sentence for the same reasons
Whether two juvenile adjudications are "sex offense conviction[s]" under U.S.S.G. § 4B1.5(a), affecting the five-level § 4B1.5(b)(1) increase	Meza: juvenile adjudications should count as convictions under § 4B1.5(a) (which would alter guideline calculation)	Government: they were used to increase offense level under § 4B1.5(b)(1); Meza sought them treated differently to reduce his guideline range	Court did not resolve the legal issue; any error would be harmless because the district court stated it would impose the same 600-month sentence and emphasized public protection and Meza's dangerousness

United States v. Ibarra-Luna, 628 F.3d 712 (5th Cir. 2010) (harmless-error standard for sentencing-guideline miscalculation requires showing the district court would have imposed the same sentence for the same reasons)
United States v. Groce, 784 F.3d 291 (5th Cir. 2015) (factors relevant to harmless-error inquiry include whether the sentence was within the properly calculated guidelines range and whether the court applied the maximum possible sentence)