United States v. Silvestre Santacruz-Hernandez, 648 F. App'x 456

Silvestre Santacruz-Hernandez, a Mexican citizen, was on supervised release after a 2009 methamphetamine distribution conviction.
A supervised-release condition prohibited committing any federal, state, or local crime.
In 2014 he illegally reentered the U.S.; he pled guilty to illegal reentry and pled “True” to violating supervised release (Grade B violation).
The probation officer erroneously listed the supervised-release Guidelines range as 6–12 months; the correct advisory range for a Grade B violation with Criminal History Category I is 4–10 months.
The district court revoked supervised release and imposed a 12-month consecutive sentence (after a 57-month illegal-reentry sentence), citing no explanation; no objection was made at sentencing.
On appeal, the Fifth Circuit found the district court relied on an incorrect Guidelines range, committed plain error, and vacated and remanded the revocation sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s reliance on an incorrect Guidelines range when revoking supervised release warrants plain-error relief	Santacruz: Court relied on incorrect (higher) Guidelines range (6–12 months vs correct 4–10), creating a reasonable probability of a lower sentence	Government: Any error was harmless because ranges overlapped and record suggests same 12-month sentence would have been imposed	Court: Plain error — the court clearly erred, the error affected substantial rights (per Molina‑Martinez), and remand is warranted because the record shows no independent basis for the 12‑month sentence

Puckett v. United States, 556 U.S. 129 (plain-error standard for unpreserved sentencing objections)
Molina‑Martinez v. United States, 136 S. Ct. 1338 (an incorrect, higher Guidelines range typically shows a reasonable probability of a different outcome)
Olano v. United States, 507 U.S. 725 (standard for correcting forfeited errors that affect fairness, integrity, or public reputation of judicial proceedings)
United States v. Davis, 602 F.3d 643 (5th Cir.) (explaining how to show reasonable probability of a different outcome under plain-error review)