United States v. Romero, No. 17-1706 (1st Cir. 2018)
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The First Circuit affirmed Defendant’s sentence of 276 months in prison for conspiracy to commit kidnapping, holding that the sentence was neither procedurally flawed nor substantively unreasonable.
After Defendant pleaded guilty to conspiracy to commit kidnapping, the district court imposed a below-guidelines sentence. On appeal, Defendant challenged the sentence’s procedural and substantive reasonableness. The First Circuit affirmed the sentence, holding (1) the ransom-demand enhancement under section 2A4.1(b)(1) of the guidelines was not plain error; (2) Defendant’s arguments regarding the judge not expressly ruling on his objections to the presentence report’s inclusion of a two-level obstruction-of-justice enhancement and rejection of a two-level minor-role reduction did not amount to procedural unreasonableness; and (3) Defendant’s sentence was substantively reasonable.
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