United States v. Sarmiento-Palacios, No. 15-2025 (1st Cir. 2018)Annotate this Case
Amendment 794 to the U.S. Sentencing Commission Guidelines clarifies the Sentencing Commission’s original intent regarding section 3B1.2 of the Sentencing Guidelines and therefore applies retroactively.
Defendant pleaded guilty to two cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). On appeal, Defendant challenged the constitutionality of the MDLEA and section 3B1.2 and argued that he should be resentenced under the Sentencing Commission’s amended guidance in Amendment 794. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding (1) Congress did not exceed its constitutional authority in promulgating the MDLEA; (2) section 3B1.2 is not void for vagueness; but (3) Amendment 794 is clarifying, not substantive, and is therefore retroactively applicable.
The court issued a subsequent related opinion or order on March 26, 2018.