1st Cir.

United States v. Figueroa-Roman

July 18, 2024 ·20-1170 ·Unpublished ·Thompson · By James Taylor

The First Circuit vacated and remanded a sentencing decision because the district court's explanation for an upward variance was ambiguous. The appellate court could not determine the meaning of the judge's reference to the defendant's association with convicted felons.

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Background

Kevin Jadiel Figueroa-Roman pleaded guilty to four counts of aiding and abetting carjacking offenses. He challenged his one hundred and eight month sentence on appeal, arguing it was procedurally unreasonable due to an inadequate explanation and reliance on unsupported factors.

The court’s reasoning

The court found that the district judge’s comment regarding the defendant’s association with convicted felons was unclear. It was uncertain whether this referred to the codefendants, their status at the time of the offense, or their status at the time of sentencing. This ambiguity prevented the appellate court from determining the standard of review or the extent to which the comment influenced the sentence.

All of this to say, the court’s comment begs many questions, and the transcript can reasonably be read in different ways.

United States v. Figueroa-Roman, 20-1170 (1st Cir. 2024)

What it means going forward

The case returns to the district court for the judge to clarify the reasoning behind the reference to convicted felons before the sentence can be finalized.