United States v. De La Cruz, No. 18-1710 (1st Cir. 2021)
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The First Circuit affirmed Defendant's sentence for several drug-related offenses, including violations of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70503 and 70506, holding that the MDLEA offenses were not eligible for "safety valve" relief under the then-applicable safety valve provision.
At the time Defendant pleaded guilty to all counts in the indictment, the MDLEA offenses carried a minimum sentence of ten years' imprisonment. Before sentencing, Defendant argued that he qualified for safety valve relief authorizing a district court to impose a sentence below the statutorily prescribed mandatory minimum sentence. The district court sentenced Defendant to the mandatory minimum sentence of ten years' imprisonment, holding that Defendant was not entitled to safety valve relief because his MDLEA offenses were not among those specifically enumerated in the safety valve statute. The First Circuit affirmed, holding that an MDLEA offense is not offense eligible for safety valve relief.
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