United States v. Torres-Santoni
673 F. App'x 10
| 1st Cir. | 2016Background
- Torres pled guilty to conspiracy to import five kilograms or more of cocaine, under 21 U.S.C. §§ 963, 952(a), 960(a)(1), 960(b)(1)(B).
- He received the statutory minimum sentence of 120 months due to §§ 963 and 960(b)(1)(B).
- Torres sought safety-valve relief under 18 U.S.C. § 3553(f) and U.S.S.G. § 5C1.2, which could have reduced the guidelines range to 87–108 months if satisfied.
- The plea agreement contains an appeal waiver: defendant waives the right to appeal if the court accepts the plea and sentences accordingly.
- A supplemental plea provision states the court may sentence below the statutory minimum only if the safety-valve requirements are fully satisfied.
- The district court ultimately concluded Torres did not satisfy the five safety-valve requirements and denied relief, and the First Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal waiver bars review of safety-valve denial | Torres | Government | Waiver does not preclude affirming on merits |
| Whether Torres qualified for safety-valve relief under § 3553(f) and § 5C1.2 | Torres sought relief to avoid the 120-month minimum | Court must independently assess compliance with safety-valve | District court did not err in finding noncompliance; no safety-valve relief |
Key Cases Cited
- United States v. Sánchez-Maldonado, 737 F.3d 826 (1st Cir. 2013) (assessing safety-valve and waivers in sentencing)
- United States v. Padilla-Colón, 578 F.3d 23 (1st Cir. 2009) (safety-valve considerations and standard of review for factual findings)