May 31, 2026 Case Explained: Nos. 24-2076, 24-2077 UNITED STATES v. CHRISTIAN DEL-VALLE-CAMACHO APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Francisco A. Besosa, U.S. District Judge] Before Barron, Chief Judge Aframe and Dunlap, Circuit Judges Jason González-Delgado was on brief for appellant Julia M. Meconiates, Assistant United States Attorney, with whom W. Stephen Muldrow, United States Attorney, and Juan Carlos Reyes-Ramos, Assistant United States Attorney, were on brief for January 14, 2026 Case: 24-2077 Document: 00118391030 Page: 1 Date Filed: 01/14/2026 Entry ID: 6778942 – 2 – DUNLAP, Circuit Judge. Defendant-Appellant Christian Del-Valle-Camacho appeals from the district court’s judgment imposing two concurrent sixty-month prison sentences for escaping from a judicially mandated re-entry program and being a felon in possession of a firearm and ammunition. Mr. Del-Valle-Camacho argues that his sentence is procedurally and substantively unreasonable because the district court imposed a nineteen-month upward variance without providing an adequate explanation based on a plausible sentencing rationale. After careful consideration we conclude that the district court provided sufficient reason to justify its upward variance — namely, the large amount of ammunition and number of magazines in Mr. Del-Valle-Camacho’s possession — and therefore affirm I Following incarceration for a federal drug trafficking conviction, Mr. Del-Valle-Camacho entered a residential re-entry facility upon the court’s order. On November 2, 2023, as Mr. Del-Valle-Camacho was returning to the facility from an approved work pass a drive-by shooting occurred and Mr. Del-Valle-Camacho ran away Staff called Mr. Del-Valle-Camacho after the shooting, and he advised them that he would return to the facility — but he never did. U.S. Marshals arrested Mr. Del-Valle-Camacho nearly two months later at a residence, where they found in plain view a Glock pistol modified Case: 24-2077 Document: 00118391030 Page: 2 Date Filed: 01/14/2026 Entry ID: 6778942 – 3 – to shoot as a machine gun, seven Glock nine-millimeter magazines of various capacities — three of thirty-one-round capacity, two of twenty-four-round capacity, one of sixteen-round capacity, and one of fourteen-round capacity — and 152 rounds of nine-millimeter ammunition Mr. Del-Valle-Camacho pled guilty to escaping from a judicially mandated re-entry program in violation of 18 U.S.C § 751 and being a felon in possession of a firearm and ammunition in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8). At sentencing, the court assessed a guideline range of thirty-three to forty-one months’ imprisonment, based on a total offense level of nineteen and criminal history category of II Mr. Del-Valle-Camacho requested a sentence of thirty-three months due to his compliance with his re-entry program before escaping as well as his acceptance of responsibility upon arrest. The government, on the other hand, requested a sentence of forty-one months, arguing that Mr. Del-Valle-Camacho’s escape demonstrated a “lack of commitment to complying with his prior sentence” and emphasizing that he was found with a modified pistol, “substantial amounts of ammunition,” and “seven magazines.” Mr. Del-Valle-Camacho also cited statistics concerning the “average” sentence imposed under the guideline applicable to his case, United States Sentencing Guidelines (“U.S.S.G.”) Case: 24-2077 Document: 00118391030 Page: 3 Date Filed: 01/14/2026 Entry ID: 6778942 – 4 – § 2K2.1.1 The court responded that those statistics were not specific to sentencing for defendants who possessed “altered” firearms or similar “number of rounds of ammunition.” The court concluded that Mr. Del-Valle-Camacho’s case “may not be an average case” because it involved “an altered pistol, plus 152 rounds of ammunition, plus seven magazines, five of which were high capacity.” Before imposing a sentence, the court noted its consideration of the sentencing factors set forth in 18 U.S.C § 3553(a), the presentence investigation report, the plea agreement, both parties’ arguments, and Mr. Del-Valle-Camacho’s allocution. Recounting the offenses, the court again highlighted that Mr. Del-Valle-Camacho “possessed a machine gun, a Glock model 19X, modified to shoot automatically, seven magazines, five of which were high capacity, and 152 rounds of 9-millimeter ammunition, while on escape status” from the residential re-entry center. It concluded that a sentence within the guideline range did not “reflect the seriousness of Mr. Del Valle’s offenses,” “promote respect for the law,” “protect the public from additional crimes b Read →
May 31, 2026 Case Explained: Nos. 24-2076, 24-2077 UNITED STATES v. CHRISTIAN DEL-VALLE-CAMACHO APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Francisco A. Besosa, U.S. District Judge] Before Barron, Chief Judge Aframe and Dunlap, Circuit Judges Jason González-Delgado was on brief for appellant Julia M. Meconiates, Assistant United States Attorney, with whom W. Stephen Muldrow, United States Attorney, and Juan Carlos Reyes-Ramos, Assistant United States Attorney, were on brief for January 14, 2026 Case: 24-2076 Document: 00118391030 Page: 1 Date Filed: 01/14/2026 Entry ID: 6778942 – 2 – DUNLAP, Circuit Judge. Defendant-Appellant Christian Del-Valle-Camacho appeals from the district court’s judgment imposing two concurrent sixty-month prison sentences for escaping from a judicially mandated re-entry program and being a felon in possession of a firearm and ammunition. Mr. Del-Valle-Camacho argues that his sentence is procedurally and substantively unreasonable because the district court imposed a nineteen-month upward variance without providing an adequate explanation based on a plausible sentencing rationale. After careful consideration we conclude that the district court provided sufficient reason to justify its upward variance — namely, the large amount of ammunition and number of magazines in Mr. Del-Valle-Camacho’s possession — and therefore affirm I Following incarceration for a federal drug trafficking conviction, Mr. Del-Valle-Camacho entered a residential re-entry facility upon the court’s order. On November 2, 2023, as Mr. Del-Valle-Camacho was returning to the facility from an approved work pass a drive-by shooting occurred and Mr. Del-Valle-Camacho ran away Staff called Mr. Del-Valle-Camacho after the shooting, and he advised them that he would return to the facility — but he never did. U.S. Marshals arrested Mr. Del-Valle-Camacho nearly two months later at a residence, where they found in plain view a Glock pistol modified Case: 24-2076 Document: 00118391030 Page: 2 Date Filed: 01/14/2026 Entry ID: 6778942 – 3 – to shoot as a machine gun, seven Glock nine-millimeter magazines of various capacities — three of thirty-one-round capacity, two of twenty-four-round capacity, one of sixteen-round capacity, and one of fourteen-round capacity — and 152 rounds of nine-millimeter ammunition Mr. Del-Valle-Camacho pled guilty to escaping from a judicially mandated re-entry program in violation of 18 U.S.C § 751 and being a felon in possession of a firearm and ammunition in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8). At sentencing, the court assessed a guideline range of thirty-three to forty-one months’ imprisonment, based on a total offense level of nineteen and criminal history category of II Mr. Del-Valle-Camacho requested a sentence of thirty-three months due to his compliance with his re-entry program before escaping as well as his acceptance of responsibility upon arrest. The government, on the other hand, requested a sentence of forty-one months, arguing that Mr. Del-Valle-Camacho’s escape demonstrated a “lack of commitment to complying with his prior sentence” and emphasizing that he was found with a modified pistol, “substantial amounts of ammunition,” and “seven magazines.” Mr. Del-Valle-Camacho also cited statistics concerning the “average” sentence imposed under the guideline applicable to his case, United States Sentencing Guidelines (“U.S.S.G.”) Case: 24-2076 Document: 00118391030 Page: 3 Date Filed: 01/14/2026 Entry ID: 6778942 – 4 – § 2K2.1.1 The court responded that those statistics were not specific to sentencing for defendants who possessed “altered” firearms or similar “number of rounds of ammunition.” The court concluded that Mr. Del-Valle-Camacho’s case “may not be an average case” because it involved “an altered pistol, plus 152 rounds of ammunition, plus seven magazines, five of which were high capacity.” Before imposing a sentence, the court noted its consideration of the sentencing factors set forth in 18 U.S.C § 3553(a), the presentence investigation report, the plea agreement, both parties’ arguments, and Mr. Del-Valle-Camacho’s allocution. Recounting the offenses, the court again highlighted that Mr. Del-Valle-Camacho “possessed a machine gun, a Glock model 19X, modified to shoot automatically, seven magazines, five of which were high capacity, and 152 rounds of 9-millimeter ammunition, while on escape status” from the residential re-entry center. It concluded that a sentence within the guideline range did not “reflect the seriousness of Mr. Del Valle’s offenses,” “promote respect for the law,” “protect the public from additional crimes b Read →
May 31, 2026 Case Explained: JAMAL J. KIFAFI, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED v. HILTON HOTELS RETIREMENT PLAN, ET AL. Read →
