United States v. Rene Sanchez
2013 U.S. App. LEXIS 7593
| 5th Cir. | 2013Background
- Diaz Sanchez pleaded guilty to unlawful reentry under 8 U.S.C. §1326(a), (b)(2).
- Probation calculated a guidelines range of 46–57 months, including a 16-level enhancement from a 2002 aggravated assault conviction.
- Diaz Sanchez requested below-guidelines or variance relief based on coercion by MS-13 and related harms, supported by letters from family.
- At sentencing, the district court adopted the PSR, considered arguments, and noted his criminal history; defense counsel requested leniency and potential reset, which the court offered but declined.
- The court imposed a 46-month sentence with no supervised release and a $100 special assessment; defense objected that the court failed to address §3553(a) factors and arguments for departure/variance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural sufficiency of sentencing explanation | Diaz Sanchez argues the court failed to address §3553(a) arguments and provide explicit reasoning. | Diaz Sanchez contends the court did not adequately consider his mitigating arguments. | Court satisfied §3553(c) by reviewing materials and engaging arguments; no procedural error. |
| Substantive unreasonableness of the sentence | Diaz Sanchez maintains the sentence does not account for hardships and mitigating factors. | Diaz Sanchez asserts the court gave insufficient weight to mitigating factors in light of coercive circumstances and prior history. | Bottom-of-guidelines sentence within range supported by totality of factors; not substantively unreasonable. |
Key Cases Cited
- Rita v. United States, 551 U.S. 338 (2007) (open-court explanation and reasons for sentence)
- Gall v. United States, 552 U.S. 38 (2007) (need for individualized assessment and not presuming guideline reasonableness)
- Mondragon-Santiago, 564 F.3d 357 (5th Cir. 2009) (limits on failure to address §3553(a) arguments in departures/variances)
- United States v. Sanchez, 667 F.3d 555 (5th Cir. 2012) (review of whether the court considered arguments and had a reasoned basis)
- Fraga, 704 F.3d 432 (5th Cir. 2013) (explanation not robotic; totality of the circumstances governs)
- Bonilla, 524 F.3d 647 (5th Cir. 2008) (focus on sentencing proceeding context to assess error)
- United States v. Cooks, 589 F.3d 173 (5th Cir. 2009) (presumption of reasonableness for within-Guidelines sentences; weighing factors)
- United States v. Rodriguez, 660 F.3d 231 (5th Cir. 2011) (deferential review; adherence to § 3553(a) factors)
- United States v. Alonzo, 435 F.3d 551 (5th Cir. 2006) (presumption of reasonableness for guideline-range sentences)