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United States v. Celaya-Romo
Citation: 180 F. App'x 236Docket: No. 05-3943-cr
Court: Court of Appeals for the Second Circuit; May 9, 2006; Federal Appellate Court
Fernando Mendez Celaya Romo appeals a judgment from July 7, 2005, after pleading guilty to conspiracy to possess with intent to distribute over five kilograms of cocaine, violating 21 U.S.C. §§ 841(b)(1)(A) and 846. He was sentenced to 168 months in prison followed by five years of supervised release. On appeal, Romo challenges the denial of a minor role adjustment under U.S.S.G. § 3B1.2(b), arguing it should be reversed or remanded for further fact-finding. He claims the District Court erroneously treated his application as a downward departure request rather than a two-point adjustment in his offense level and failed to consider the sentencing factors outlined in 18 U.S.C. § 3553(a). The appellate court emphasizes its authority to review sentences for reasonableness. It finds no merit in Romo's claim regarding the minor role adjustment, stating that the District Court's conclusion was supported by the evidence showing Romo was significantly involved, having been entrusted with a substantial quantity of cocaine and having engaged in similar activities previously. The court notes that a district court’s evaluation of a defendant's role is fact-specific and did not constitute legal error or rely on clearly erroneous facts. Furthermore, the court clarifies that the District Court's reference to the minor role adjustment as a “downward departure” does not indicate a misunderstanding of the request, as the record shows the Court assessed the application as intended for a two-point reduction in the offense level. A strong presumption exists that a sentencing judge has considered all relevant arguments unless the record indicates otherwise. In this case, there is no evidence suggesting that the District Court misunderstood the law or the defendant’s application. Trial judges are presumed to know and apply the law appropriately. The defendant's assertion that the District Court provided only superficial consideration of the sentencing factors outlined in 18 U.S.C. § 3553(a) is unfounded. Prior rulings affirm that detailed discussions of each factor are not required to demonstrate consideration. The District Court explicitly stated that the 168-month sentence aligns with § 3553(a) by taking into account the nature of the offense and the defendant's characteristics, aiming to promote respect for the law and deter criminal behavior. Although the defendant argued that the court's mention of the federal sentencing guidelines implied a presumption for a guidelines sentence, this interpretation does not negate the clear record indicating the court's awareness of its authority to impose a non-guidelines sentence and its obligation to consider all § 3553(a) factors. The court followed the procedural framework from United States v. Crosby and imposed a reasonable sentence. All of the defendant's arguments on appeal were found to lack merit, leading to the affirmation of the District Court's judgment.