3rd Cir.

UNITED STATES OF AMERICA v. MIGUEL EDUARDO ROSARIO

July 1, 2026 ·23-1242 ·Panel Decision ·ROTH · By James Taylor

The Third Circuit affirmed the appellant's drug trafficking and firearm convictions but vacated his mandatory life sentence for remand.

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Background

Miguel Rosario was convicted by a jury for drug offenses resulting in the death of Nicholas Correa and for accepting firearms as payment for drugs. The conviction relied on evidence seized via a search warrant for Rosario’s Facebook communications. Rosario challenged the warrant’s validity under the Fourth Amendment and the sufficiency of the evidence, while also contesting the mandatory life sentence imposed under federal statute.

The court’s reasoning

The court applied the good faith exception to the exclusionary rule and found no clear error in the district court’s determination that the affiant did not act with reckless disregard for the truth. The court held that the medium of communication did not vitiate the probable cause finding. However, the court vacated the sentence, indicating a need for resentencing.

For the following reasons, we will affirm Rosario’s convictions. However, we will vacate his sentence and remand to the District Court for resentencing.

What it means going forward

Defendants challenging search warrants based on minor affidavit discrepancies face a high bar to prove reckless disregard, but mandatory minimum sentences may still be subject to appellate review and remand.