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United States v. Ayala-Sanabria

Citation: 36 F. App'x 919Docket: No. 01-50685; D.C. No. CR-00-03536-TJW

Court: Court of Appeals for the Ninth Circuit; May 29, 2002; Federal Appellate Court

Narrative Opinion Summary

In this appellate case, the defendant challenges the district court's imposition of a 24-month sentence following his conviction for illegal re-entry into the United States under 8 U.S.C. § 1326(a). Jurisdiction was confirmed under 28 U.S.C. § 1291 and 18 U.S.C. § 3742. The defendant disputed the classification of a prior conviction for second-degree burglary as an aggravated felony, arguing that California Penal Code § 459 covers broader conduct than the federal definition of burglary per Taylor v. United States. Nevertheless, the district court found sufficient evidence aligning with the federal criteria. Additionally, the appellant's claim of rights violation under Apprendi was dismissed, referencing precedent from United States v. Pacheco-Zepeda. The defendant also contested the denial of an adjustment for acceptance of responsibility under U.S.S.G. § 3E1.1, which the court upheld, noting the absence of exceptional circumstances. The appellate court affirmed the district court’s decisions, rendering the opinion non-publishable under Ninth Circuit Rule 36-3.

Legal Issues Addressed

Acceptance of Responsibility under U.S.S.G. § 3E1.1

Application: The court upheld the district court's decision not to grant an adjustment for acceptance of responsibility, noting the defendant did not meet rare exceptions.

Reasoning: Lastly, Ayala-Sanabria challenges the district court's refusal to grant an adjustment for acceptance of responsibility under U.S.S.G. § 3E1.1, asserting that he accepted responsibility despite going to trial.

Application of Sentencing Guidelines and Standard of Review

Application: The court analyzed the district court's interpretation and application of Sentencing Guidelines de novo and reviewed factual determinations for clear error.

Reasoning: The court reviews the district court's interpretation and application of the Sentencing Guidelines de novo and assesses factual determinations for clear error.

Apprendi v. New Jersey and Rights Infringement Claims

Application: The court dismissed claims of rights infringement under Apprendi based on established precedent.

Reasoning: He also contends that the district court infringed upon his rights under Apprendi v. New Jersey. This claim is dismissed based on precedent set in United States v. Pacheco-Zepeda.

Classification of Aggravated Felony under 8 U.S.C. § 1326(a)

Application: The court evaluated whether a prior burglary conviction qualifies as an aggravated felony under the federal definition.

Reasoning: Ayala-Sanabria argues that his 1986 second-degree burglary conviction under California Penal Code § 459 should not be classified as an aggravated felony, as the state statute encompasses conduct beyond the federal definition of burglary as established in Taylor v. United States.