Unreported / Non-Citable
Background
Sebastian Cruz-Amaya was convicted of smuggling goods from the United States in the Southern District of Texas. The district court sentenced him to 24 months in prison.
In calculating the sentence, the district court applied a 14-level enhancement under U.S.S.G. §§ 2Q2.1(b)(3)(A)(ii) and 2B1.1(b)(1)(H). Cruz-Amaya appealed, arguing that the conduct used to support that enhancement should not have been treated as relevant conduct.
The Court’s Holding
The Fifth Circuit affirmed. Reviewing the district court’s relevant-conduct determination for clear error, the panel held that the determination was plausible in light of the record as a whole.
The evidence showed that the conduct was part of a common plan or scheme or, alternatively, constituted the same course of conduct under U.S.S.G. § 1B1.3. The district court therefore did not clearly err in using that conduct to apply the 14-level enhancement.
Key Takeaways
- A district court’s relevant-conduct determination is reviewed for clear error.
- Conduct may support a Guidelines enhancement when it is part of a common plan or scheme or the same course of conduct as the offense of conviction.
- The Fifth Circuit upheld Cruz-Amaya’s 14-level enhancement and 24-month sentence.
Why It Matters
The decision illustrates the breadth of relevant-conduct principles in federal sentencing. Conduct beyond the specific offense of conviction may substantially increase the Guidelines calculation when the record plausibly connects it to the offense through a common scheme or the same course of conduct.
It also underscores the deference appellate courts give to fact-based relevant-conduct findings under clear-error review.