United States v. Bravo, No. 20-1105 (7th Cir. 2022)
Annotate this Case
Indictments alleged that the Latin Kings had been involved in multiple acts of murder, arson, robbery, extortion, witness tampering, and the illegal distribution of narcotics. The three defendants were charged with racketeering conspiracy, 18 U.S.C. 1962(d). Bravo and Denava pleaded guilty while Luczak was convicted.
In consolidated appeals, Bravo argued that the district court erred by adding criminal history points for two misdemeanor convictions he had under the Illinois “street-gang contact” statute. Luczak claimed that the district court should not have included, as part of his criminal history, points for a murder he allegedly committed; a jury had acquitted him of that offense, using the reasonable-doubt standard, but the court found at sentencing that his responsibility for the murder was established by a preponderance of the evidence. Denava claimed that the district court failed adequately to consider several mitigating factors under 18 U.S.C. 3553(a).
The Seventh Circuit reversed in part. The district court erred in counting Bravo’s two misdemeanor offenses toward his criminal history, and that error may have affected his ultimate sentence. The court noted the street-gang contact statute was amended in 2018 in a matter that might render Bravo’s street-gang contacts non-criminal today. There was no error in Luczak’s and Denava’s sentences.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.