United States v. Roberto Guzman-Ramirez, 949 F.3d 1034

In 2016 a supplier in Mexico arranged for 50 kg of cocaine to be transported to Chicago; Gonzalez would drive the semi-trailer from Texas and Guzman‑Ramirez would meet him in Chicago to help remove and transfer the drugs.
Guzman‑Ramirez agreed to transport and store half the load in Milwaukee and served as the supplier’s point of contact; he demonstrated knowledge of the compartment and quantity.
The unloading attempt in Chicago was aborted for logistical reasons; law enforcement seized 50.12 kg of cocaine the next day.
Guzman‑Ramirez pled guilty to conspiracy to possess with intent to distribute 5+ kg of cocaine; PSR did not recommend a minor‑role reduction and set total offense level (after safety valve) at 29 (87–108 months).
The district court denied a §3B1.2 minor‑role reduction but granted safety‑valve relief and sentenced Guzman‑Ramirez to 72 months (15 months below the Guidelines range).
Six weeks later a different judge sentenced Gonzalez (same conspiracy) and granted a §3B1.2 minor‑role reduction, producing a lower Guidelines range and a 48‑month sentence.

Issue	Guzman‑Ramirez's Argument	Government's/Respondent's Argument	Held
Whether Guzman‑Ramirez is entitled to a minor‑role reduction under U.S.S.G. §3B1.2	He was merely a courier who transported/stored drugs and lacked decision‑making authority	He was at least as culpable as the average participant: contact person, agreed to store half the load, knew compartment/amount	Denied—district court’s factual findings that he wasn’t substantially less culpable than average were not clearly erroneous
Whether Guzman‑Ramirez’s sentence is unreasonable because Gonzalez later received a lower sentence	Sentencing disparity with Gonzalez shows unreasonableness	Court need not (and could not) consider a coconspirator’s sentence not yet imposed; below‑Guidelines sentence is presumptively reasonable	Denied—no abuse of discretion; later lower sentence for Gonzalez does not render Guzman‑Ramirez’s sentence unreasonable

United States v. Orlando, 819 F.3d 1016 (7th Cir. 2016) (minor‑role comparison is to the average participant; below‑Guidelines sentences are presumptively reasonable)
United States v. Campuzano‑Benitez, 910 F.3d 982 (7th Cir. 2018) (enumerates factors for assessing role: knowledge, planning, decision‑making, financial gain)
United States v. Tartareanu, 884 F.3d 741 (7th Cir. 2018) (district court role findings reviewed for clear error)
United States v. Leiskunas, 656 F.3d 732 (7th Cir. 2011) (a courier role can still qualify as minor; determination is fact‑specific)
United States v. Sandoval‑Velazco, 736 F.3d 1104 (7th Cir. 2013) (compare defendant’s role to other participants in same conspiracy)
Smith v. United States, 568 U.S. 106 (2013) (withdrawal from conspiracy requires affirmative action to disavow or defeat the conspiracy’s purpose)
United States v. Cardena, 842 F.3d 959 (7th Cir. 2016) (a judge cannot be faulted for failing to consider coconspirators’ sentences that have not yet been imposed)
United States v. Porraz, 943 F.3d 1099 (7th Cir. 2019) (same principle regarding consideration of coconspirators’ later sentences)
United States v. Lazenby, 439 F.3d 928 (8th Cir. 2006) (consolidated appeals can permit appellate correction of disparate sentences when both sides appeal)