Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. DARWIN JOSE MARTINEZ ANCHUNDIA

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-02

Docket: 8:24-cr-00500-SDM-TGW-4

The Eleventh Circuit affirmed the district court’s imposition of a 108-month sentence on Darwin Jose Martinez Anchundia for conspiracy to distribute cocaine and possession with intent to distribute, rejecting his claim that the sentence was procedurally unreasonable due to the failure to apply a minor-role reduction. The court applied the clear error standard of review, noting that the district court has considerable discretion in determining whether a defendant qualifies for an adjustment under U.S.S.G. § 3B1.2(b). Under this guideline, a minor participant is one less culpable than most other participants but not minimal. The opinion emphasizes that a defendant bears the burden of proving by a preponderance of the evidence that they played a minor role in the specific conduct for which they were held accountable. The court reasoned that Anchundia was accountable for transporting 4,230 kilograms of cocaine and understood the nature of his trafficking conduct, even if he lacked decision-making power regarding the broader conspiracy. Citing *United States v. De Varon* and *United States v. Gruezo*, the court held that a defendant cannot claim a minor role simply by comparing themselves to participants in a broader scheme for which they were not held accountable. Because Anchundia was responsible for transporting a significant quantity of drugs worth millions of dollars, his involvement was deemed serious enough to deny the adjustment. Consequently, the district court’s decision is upheld, and the sentence remains in effect.

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