United States v. Rodriguez-Melendez
828 F.3d 35
| 1st Cir. | 2016Background
- Rodríguez‑Meléndez completed a sentence for a drug‑trafficking conviction and began an eight‑year term of supervised release on June 14, 2012.
- Police executed a search warrant on January 31, 2014, seizing a .40 pistol, magazines/ammunition, and at least 40 grams of cocaine; Probation filed a motion alleging violations including possession of a firearm and a controlled substance.
- Rodríguez‑Meléndez conceded the supervised‑release violation and separately pled guilty in a parallel criminal case to possessing a firearm in furtherance of a drug‑trafficking crime (18 U.S.C. § 924(c)).
- At the revocation hearing the district court imposed the statutory maximum of 36 months (above the Guidelines range), citing in part that Probation Office records showed he "tested positive a couple of times."
- Two days earlier, the Presentence Investigation Report (PSR) in the parallel criminal case—prepared by the Probation Office—stated urine tests were negative and that the defendant had not ingested illegal drugs while on supervised release.
- The First Circuit concluded the district court relied on a demonstrably false factual premise (positive drug tests) when sentencing and vacated the revocation sentence, remanding for resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentence was procedurally reasonable given the court relied on inaccurate Probation Office records | Rodríguez‑Meléndez argued the court relied on a false fact (that he tested positive) which affected sentencing | Government argued the court likely referred to alcohol or non‑drug allegations and that no clear error occurred | Court held there was clear, obvious error: the PSR contradicted the court's statement that he tested positive for drugs, so sentence was procedurally unreasonable |
| Whether the error affected substantial rights (plain‑error standard) | Error likely influenced the upward variance; without it a lower sentence was reasonably probable | Government contended drug‑use was not alleged and sentencing driven by weapon possession and new offense | Court held reasonable probability the error affected outcome; substantial rights were affected |
| Whether the error seriously impaired fairness/integrity of proceedings | Rodríguez‑Meléndez argued reliance on demonstrably wrong fact undermined sentencing integrity | Government maintained other valid aggravating factors justified sentence | Court held reliance on a demonstrably wrong fact between related proceedings did seriously impair fairness and public confidence |
| Remedy: vacatur and remand required? | Requested vacatur and resentencing to be based on correct facts | Government opposed vacatur given other aggravating factors | Court vacated the sentence and remanded for resentencing (did not decide substantive‑reasonableness claim) |
Key Cases Cited
- Gall v. United States, 552 U.S. 38 (sentencing based on clearly erroneous facts is an abuse of discretion)
- United States v. Portalla, 985 F.2d 621 (revocation‑hearing evidence must be reliable)
- United States v. Roy, 506 F.3d 28 (plain‑error test elements; fairness/integrity prong explained)
- United States v. González‑Castillo, 562 F.3d 80 (establishing reasonable‑probability standard for prejudice in sentencing error)
- United States v. Perazza‑Mercado, 553 F.3d 65 (same prejudice standard applied to revocation sentencing)