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United States v. Mora-Perez

Citation: 17 F. App'x 717Docket: No. 00-30231; D.C. No. CR-99-00027-f-JMF

Court: Court of Appeals for the Ninth Circuit; August 31, 2001; Federal Appellate Court

Narrative Opinion Summary

In this case, the appellate court reviewed the sentencing decision for an individual, Mora-Perez, convicted of drug-related offenses. The court asserted its jurisdiction under 28 U.S.C. 1291 and upheld the district court's sentence. Mora-Perez contended that his confession required governmental corroboration to be admissible at sentencing; however, the court rejected this claim, emphasizing that the procedural safeguards applicable in trials do not extend to sentencing. The court confirmed that sentencing guidelines allow consideration of any reliable information, which Mora-Perez did not effectively contest. The district court's findings on drug quantity were based on Mora-Perez's confession and a probation officer’s estimates, which aligned with the sentencing guidelines permitting estimations based on similar transactions. The court's reliance on uncorroborated reports was deemed acceptable as Mora-Perez failed to prove their unreliability. The appellate court reviewed the district court's factual findings for clear error and the estimation method de novo, ultimately affirming the lower court's cautious approach in quantifying drug amounts. The decision was affirmed, with limitations on its publication and citation as per Ninth Circuit Rule 36-3.

Legal Issues Addressed

Admissibility of Confession at Sentencing

Application: Confessions do not require government corroboration to be admissible during sentencing proceedings.

Reasoning: The court dismisses Mora-Perez’s claim that his confession required government corroboration for it to be admissible at sentencing, noting that the procedural safeguards applicable in trials do not apply during sentencing.

Consideration of Information at Sentencing

Application: Sentencing guidelines permit the consideration of any information with adequate reliability.

Reasoning: The sentencing guidelines allow for the consideration of any information with adequate reliability, which Mora-Perez failed to challenge effectively.

Determination of Relevant Conduct

Application: Relevant conduct is determined by similarities to the offense of conviction and requires specific repeated events.

Reasoning: Relevant conduct is determined by similarities to the offense of conviction, and this determination is reviewed for clear error.

Estimation of Drug Quantities under Sentencing Guidelines

Application: The court may estimate drug quantities based on similar transactions when precise data is unavailable.

Reasoning: The district court accepted a Probation Officer's estimate of 2.5 kilograms, which falls within the authority granted to the court by Section 2D1.1 of the sentencing guidelines to estimate drug quantities based on similar transactions.

Jurisdiction under 28 U.S.C. 1291

Application: The court has jurisdiction to review the sentencing decision of Mora-Perez.

Reasoning: Jurisdiction is established under 28 U.S.C. 1291, and the court affirms the decision regarding Mora-Perez’s sentencing.

Reliance on Uncorroborated Officer Reports

Application: Sentencing judges are permitted to rely on uncorroborated officer reports unless the defendant demonstrates their unreliability.

Reasoning: Sentencing judges may rely on uncorroborated officer reports, with the defendant bearing the burden of demonstrating their unreliability.

Standard of Review for Factual Findings

Application: The district court's factual findings are reviewed for clear error, and the method to estimate drug quantities is reviewed de novo.

Reasoning: The district court's factual findings are also reviewed for clear error. The method used by the district court to estimate drug quantities is reviewed de novo.