United States v. Vega-Rivera, 866 F.3d 14

On April 14, 2015, Vega led Guaynabo municipal police on a high‑speed traffic chase near a university and commercial area, crashed into another vehicle, fled on foot carrying a loaded Glock 23 modified to fire fully automatic, and discarded the gun in a bank parking lot before surrendering.
The recovered handgun was loaded (one round chambered) and had a 22‑round magazine with 20 rounds; two additional loaded 20‑round magazines and a bullet‑proof vest were found in Vega’s car; the gun was stolen and moved in interstate commerce.
Vega waived rights and admitted purchasing the modified Glock three days earlier and that he was a convicted felon (prior narcotics conviction).
Vega pled guilty to (1) possession of a firearm by a convicted felon (18 U.S.C. § 922(g)(1)) and (2) possession of a machine gun (18 U.S.C. § 922(o)); plea agreement set offense level at 19 but left Criminal History Category open.
The PSR added a two‑level enhancement under U.S.S.G. § 3C1.2 for reckless endangerment during flight, producing offense level 21 and Criminal History Category III (range 46–57 months); district court applied the enhancement and sentenced Vega to 57 months and 3 years supervised release with curfew and electronic monitoring.

Issue	Vega's Argument	Government's Argument	Held
Whether § 3C1.2 two‑level enhancement for recklessly creating a substantial risk during flight applies	Vega: his conduct was not reckless to the degree required and did not create a substantial risk (did not brandish/shoot, no injuries)	Govt: high‑speed chase, crash in busy area, fleeing with loaded automatic gun and discarding it in public created substantial risk	Enhancement affirmed: conduct was reckless and created a substantial risk; district court’s factual findings not clearly erroneous
Whether curfew and electronic monitoring as supervised‑release conditions were an abuse of discretion	Vega: conditions not reasonably related to offense/history and are greater deprivation than necessary	Govt: conditions reasonably related to Vega’s weapons history, prior drug convictions, need for deterrence and public protection	Conditions affirmed: sufficiently related to offense, history, and supervisory goals
Whether the sentence (57 months) is substantively unreasonable	Vega: court failed adequately to weigh arguments for lower Guidelines sentence	Govt: sentence within properly calculated Guidelines and supported by record	Sentence affirmed as substantively reasonable: court gave plausible rationale and result fits Guidelines

United States v. Carrero‑Hernández, 643 F.3d 344 (1st Cir.) (recklessness and § 3C1.2 standard)
United States v. Jimenez, 323 F.3d 320 (5th Cir.) (high‑speed pursuits through populated areas support § 3C1.2)
United States v. Velasquez, 67 F.3d 650 (7th Cir.) (flight through residential neighborhoods supports § 3C1.2)
United States v. York, 357 F.3d 14 (1st Cir. 2004) (permissible supervised‑release conditions must relate to offense, history, deterrence, protection, or treatment)
United States v. Garrasteguy, 559 F.3d 34 (1st Cir. 2009) (standard of review for supervised‑release conditions)
United States v. Zapata‑Vázquez, 778 F.3d 21 (1st Cir.) (hallmarks of substantive reasonableness: plausible rationale and defensible result)