United States v. Roberto Sandoval-Velazco, 2013 U.S. App. LEXIS 24152

Sandoval-Velazco participated from ~2009 in a Chicago-based DTO that distributed large quantities of cocaine, heroin, and marijuana; he primarily acted as a courier and transported drug proceeds.
PSR attributed to him responsibility for over 150 kg of cocaine and 8.5 kg of heroin (equivalent to ~46,400 kg marijuana), yielding a base offense level 38, reduced three levels for acceptance.
He pled guilty to multiple drug offenses (including conspiracy and possession with intent to distribute) and sought a 2–3 level mitigating-role reduction under U.S.S.G. §3B1.2 as a minor participant.
The probation officer declined a role reduction, finding him fully active; the government argued he was an average participant who transported large amounts and proceeds for an extended period.
The district court denied the minor-role reduction and, after considering but rejecting arguments for a below-guidelines sentence, imposed 135 months (the lowest within the guideline range).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sandoval-Velazco was entitled to a minor-role reduction under U.S.S.G. §3B1.2	He was only a courier, subordinate, lacked decisionmaking authority, and was substantially less culpable than average participants	He had an intimate, substantial connection to large drug quantities over a long period and thus was not substantially less culpable	Denial of minor-role reduction affirmed — court found quantity, duration, and duties showed he was not substantially less culpable
Whether the district court procedurally erred by failing to recognize authority to impose a below-guidelines sentence	Court appeared to suggest Congressional policy constrained it, implying possible unawareness of below-guidelines authority	Court considered §3553(a) factors and consciously imposed a guideline sentence; it understood it could depart/variance	No procedural error — court understood its authority and permissibly chose a guideline sentence

Abbas v. United States, 560 F.3d 660 (7th Cir.) (standard of review for guideline interpretation)
Miller v. United States, 405 F.3d 551 (7th Cir.) (clear-error review of role-reduction denials)
Leiskunas v. United States, 656 F.3d 732 (7th Cir.) (deference to sentencing court’s role findings)
Panaigua-Verdugo v. United States, 537 F.3d 722 (7th Cir.) (burden on defendant to prove minor role; couriers not automatically entitled to reduction)
Gonzalez v. United States, 534 F.3d 613 (7th Cir.) (defendant must show substantially less culpable than average participant)
Diaz-Rios v. United States, 706 F.3d 795 (7th Cir.) (quantity may be considered but court must evaluate role relative to others)
Gallardo v. United States, 497 F.3d 727 (7th Cir.) (quantity can inform culpability assessment)
Corner v. United States, 598 F.3d 411 (7th Cir.) (district courts may categorically disagree with Guidelines under §3553(a))
Pulley v. United States, 601 F.3d 660 (7th Cir.) (de novo review of sentencing procedure questions)
Taylor v. United States, 520 F.3d 746 (7th Cir.) (remand required when court unaware of its authority to impose non-guideline sentence)