Case Explained: UNITED STATES OF AMERICA v. KEVIN JADIEL FIGUEROA-ROMAN

Court: United States Court of Appeals for the First Circuit

Filed: 2026-07-16

The First Circuit vacated the defendant’s 108-month prison sentence and remanded the case to the District Court for clarification regarding the sentencing rationale. The court held that its ability to conduct meaningful appellate review was obstructed by an ambiguous statement made by the district judge during the sentencing colloquy, specifically the reference to balancing the defendant’s “association with convicted felons” against his lack of a criminal record. The court applied the standard requiring that a sentencing court provide a clear explanation sufficient for appellate review, citing *United States v. Colón-Cordero* and *United States v. Serrano-Berríos*. The panel determined that it was unclear whether the judge referred to the defendant’s codefendants, other individuals, or future associations, and at what point in time these “felons” were convicted. Because the transcript supported multiple plausible interpretations of this comment, the court could not discern whether the statement constituted a factual finding, a reference to record evidence, or an impermissible consideration that would affect the standard of review or the validity of the upward variance. The practical consequence is that the District Court must clarify the meaning and significance of its “association with convicted felons” comment on remand. The panel explicitly noted that it leaves untouched any other questions regarding the adequacy of the sentencing explanation and does not intimate a view on whether the sentence was ultimately appropriate, but rather seeks to resolve the ambiguity to allow for proper appellate analysis.

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