United States v. Roman Centeno-Guerrero
673 F. App'x 427
| 5th Cir. | 2017Background
- Roman Centeno-Guerrero moved for a sentence reduction under 18 U.S.C. § 3582(c)(2) following an amendment to the sentencing guidelines.
- The district court denied the motion; Centeno-Guerrero appealed that denial.
- He argued the court wrongly concluded he was ineligible because his original sentence was not within the then-applicable guidelines range.
- Alternatively, he argued that even if eligible, the court failed to properly reconsider the 18 U.S.C. § 3553(a) sentencing factors before denying relief.
- The district court’s written order set out the original and amended guideline ranges; the panel found the record showed an implicit determination of eligibility and that the court considered § 1B1.10, the § 3553(a) factors, and mitigating information.
- The Fifth Circuit reviewed for abuse of discretion and affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Centeno-Guerrero was eligible for a § 3582(c)(2) reduction | District court erred by finding him ineligible because his original sentence was not within the applicable guidelines range | District court implicitly found eligibility; written order showed amended and original ranges | Court: implicit eligibility finding sufficed; eligibility established |
| Whether the district court abused its discretion by not properly reevaluating § 3553(a) factors | Even if eligible, court failed to meaningfully reconsider § 3553(a) and mitigating evidence | District court considered the § 1B1.10 policy statement, § 3553(a) factors, and mitigating submissions but declined relief in its discretion | Court: no abuse of discretion; district court adequately considered § 3553(a) and could deny relief despite eligibility |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (establishes two-step § 3582(c)(2) inquiry)
- United States v. Henderson, 636 F.3d 713 (standard for abuse of discretion review)
- United States v. Larry, 632 F.3d 933 (implicit eligibility determination is sufficient)
- United States v. Evans, 587 F.3d 667 (district court not required to grant reduction even if eligible)
- United States v. Whitebird, 55 F.3d 1007 (abuse of discretion framework)