1st Cir.

UNITED STATES OF AMERICA v. KEVIN JADIEL FIGUEROA-ROMAN

July 16, 2026 ·20-1170 ·Unpublished ·Thompson · By James Taylor

The United States Court of Appeals for the First Circuit vacated and remanded a sentencing decision due to ambiguity in the district court's reasoning. The appellate court found it could not conduct meaningful review because the judge's reference to the defendant's association with convicted felons was unclear.

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Background

Kevin Jadiel Figueroa-Roman pleaded guilty to four counts of aiding and abetting carjackings. He received a sentence of one hundred and eight months imprisonment on each count, served concurrently. On appeal, he argued the sentence was procedurally unreasonable because the court inadequately explained its rationale and relied on unsupported factors.

The court’s reasoning

The appellate panel determined that the district court’s comment regarding the defendant’s association with convicted felons was ambiguous. The court could not discern whether the judge referred to the codefendants, their status at the time of the offense, or their future status. This uncertainty prevented the appellate court from determining the standard of review or assessing the weight given to that factor in the sentencing decision.

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 district court must clarify the meaning of its reference to the defendant’s association with convicted felons before resentencing can proceed.