Background
Jhonaker Manuel Arrieta, a Venezuelan citizen detained at an Immigration and Customs Enforcement facility in El Paso, participated in a standoff with six other detainees. They climbed to a roof two stories above the ground using makeshift ropes and refused commands to descend for over three and a half hours. The facility remained on lockdown for six hours, suspending dining and cutting off access to attorneys and families. Arrieta pleaded guilty to mutiny under eighteen U.S.C. section one seven nine two. The district court sentenced him to fifteen months of imprisonment, three years of supervised release, and a one hundred dollar special assessment, applying a base offense level of sixteen under U.S.S.G. section two point one point three.
The court’s reasoning
The Fifth Circuit reviewed the district court’s factual finding for clear error and its interpretation of the Guidelines de novo. The court determined that the phrase major disruption to the operation of an institution requires an interruption that is important, serious, or significant. The court found that the six-hour lockdown, which canceled activities and suspended dining, was not a minor administrative disruption but a major operational halt. The court noted that the standoff required two specialized law enforcement teams and sublethal munitions to resolve. The court concluded that the district court’s finding was plausible in light of the whole record and affirmed the sentence.
The facility stayed on total lockdown for six hours—canceling activities, turning away visitors and counsel, and serving a satellite dinner because regular dining was unavailable.
United States v. Arrieta, No. 25-50510, slip op. at 2 (5th Cir. June 29, 2026)
What it means going forward
The decision clarifies that a prolonged standoff requiring specialized response and resulting in a multi-hour facility lockdown qualifies as a major disruption under the Sentencing Guidelines, warranting a base offense level of sixteen rather than the residual level of ten.