United States v. Maldonado-Rios, No. 14-1357 (1st Cir. 2015)
Annotate this CaseAppellant pled guilty to possession with intent to distribute more than five kilograms of cocaine. After he was sentenced, Appellant appealed, arguing that the district court erred by inadequately explaining its reasons for choosing a 135-month sentence rather than the 120-month mandatory minimum. While Appellant’s appeal was pending, the sentencing guidelines were amended so as to lower the sentencing range for most drug offenses. The amendment was made retroactive. As a result, Appellant moved to have the district court modify his sentence. While the appeal was still pending, the district court issued an order purporting to reduce Appellant’s sentence to the 120-month minimum in consequence of the amendment. However, the district court did not issue an indicative ruling in accordance with Fed. R. App. P. 12.1. The First Circuit (1) held that the district court lacked jurisdiction to enter the order reducing the sentence because Appellant’s appeal was pending at the time the district court ruled on Appellant’s motion to modify the sentence; and (2) treated the district court’s order as though it were an indicative ruling under Rule 12.1. The Court then remanded to the district court to enter an order modifying Defendant’s sentence as the amendment to the sentencing guidelines warranted.
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