UNITED STATES OF AMERICA v. ANGELICA MENDOZA RUBIO

Holding: The Seventh Circuit affirmed the district court's sentence, holding that the defendant qualified for a role enhancement and that the sentence did not constitute an unwarranted disparity.
Standard: U.S.S.G. § 3B1.1(b) role enhancement; 18 U.S.C. § 3553(a)(6) disparity consideration
Vote: Panel Decision
Practical effect: The decision clarifies that a defendant can be deemed a manager or supervisor under the sentencing guidelines even if they did not recruit accomplices or earn the largest share of profits, provided they exercised control over the operation's coordination.

The Seventh Circuit affirmed a money laundering conviction and sentence, rejecting arguments that the defendant did not qualify for a role enhancement. The court held that the defendant exercised sufficient control over coconspirators to warrant a manager or supervisor enhancement under the sentencing guidelines.

Background

Defendant Angelica Mendoza Rubio pleaded guilty to conspiracy to commit money laundering involving more than five million dollars in fraud proceeds. She acted as a broker converting cash to Bitcoin and coordinated activities between cash carriers and account holders. The district court applied a three-level role enhancement and sentenced her to sixty months imprisonment, which was below the guidelines range but within the plea agreement.

The court’s reasoning

The court reviewed the role enhancement de novo and found the district court did not clearly err. The record showed Mendoza Rubio directed and managed coconspirators, tracked cash pickups, and controlled Bitcoin purchases. The court noted that control need not include the power to dictate actions but can involve orchestrating activities or delegating tasks. Regarding sentencing disparities, the court held that a below-guidelines sentence within a binding plea agreement range necessarily considers the need to avoid unwarranted disparities between coconspirators.

Mendoza Rubio was more than just a middleman or a go-between between her coconspirators and clients.

UNITED STATES OF AMERICA v. ANGELICA MENDOZA RUBIO, No. 25-2380 (7th Cir. July 21, 2026)

What it means going forward

The decision clarifies that a defendant can be deemed a manager or supervisor under the sentencing guidelines even if they did not recruit accomplices or earn the largest share of profits, provided they exercised control over the operation’s coordination.