Case Explained: USA V. SANTANA

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-15

Docket: 1:24-cr-00022-LEK-1

The Ninth Circuit affirmed the district court’s judgment sentencing Shawn Pauahi Santana to 240 months of imprisonment followed by five years of supervised release for conspiracy to distribute methamphetamine and possession with intent to distribute. The court held that the district court did not plainly err in calculating Santana’s criminal history score under U.S.S.G. § 4A1.2(e)(2) by crediting his 2013 domestic battery and DUI sentences, as Santana admitted the instant offense began by October 2022, placing those prior convictions within the ten-year lookback period. Furthermore, the court ruled that the district court was not required to explicitly rule on Santana’s request for “safety valve” relief under 18 U.S.C. § 3553(f) because its finding that Santana acted as an organizer, leader, manager, or supervisor under U.S.S.G. § 3B1.1(c) categorically rendered him ineligible for such relief pursuant to 18 U.S.C. § 3553(f)(4). Although Santana argued that the district court’s oral statements vitiated his appellate waiver in the plea agreement, the court assumed without deciding that he could overcome the waiver but concluded his claims failed on the merits. Consequently, the judgment is affirmed and no further action is required.

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