United States v. Rodríguez-Meléndez, 828 F.3d 35

Rodríguez-Meléndez completed a sentence for a drug-trafficking conviction and began an eight-year term of supervised release in 2012.
Police executed a search in January 2014 and seized a .40 caliber pistol, magazines with ammunition, and at least 40 grams of cocaine; Probation moved to revoke for possession of a firearm and controlled substances.
Rodríguez-Meléndez conceded the supervised-release violation and pled guilty in a separate proceeding to possessing a firearm in furtherance of a drug-trafficking crime; revocation was mandatory.
At the revocation sentencing hearing the district court imposed the statutory maximum of 36 months — above the Guidelines range and the government’s recommendation — citing, among other things, that Probation records showed Rodríguez-Meléndez had “tested positive a couple of times.”
The Presentence Investigation Report (PSR) prepared by Probation two days earlier stated the opposite: urine tests during supervised release were negative and the defendant had not ingested illegal drugs while on federal supervision.
The First Circuit concluded the district court relied on a demonstrably false fact (positive drug tests), applied plain-error review, found the error was clear, affected substantial rights, and vacated the revocation sentence, remanding for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural reasonableness of revocation sentence	Rodriguez argued court relied on inaccurate probation records (positive drug tests), producing procedural error	Government argued Probation alleged excessive alcohol use and that the court’s remarks did not rely on misreported drug tests	Court held district court clearly and obviously relied on a demonstrably false fact (it twice stated defendant tested positive), constituting procedural error requiring vacatur
Effect on substantial rights / plain-error standard	Rodriguez argued the false fact likely affected sentence choice and thereby his substantial rights	Government argued the sentence was justified by the serious gun-related violation and danger to community	Court held there was a reasonable probability the erroneous drug-use finding influenced the above-Guidelines sentence, affecting substantial rights and impairing fairness, so relief warranted

Gall v. United States, 552 U.S. 38 (selecting sentence based on clearly erroneous facts is an abuse of discretion)
United States v. Portalla, 985 F.2d 621 (1st Cir.) (evidence used in revocation hearings must be reliable)
United States v. Roy, 506 F.3d 28 (1st Cir.) (standards for plain-error review)
United States v. Dávila-González, 595 F.3d 42 (1st Cir.) (appellate standard when defendant failed to raise claim below)
United States v. González-Castillo, 562 F.3d 80 (1st Cir.) (reasonable-probability standard for prejudice under plain-error review)