United States v. Zambrano, No. 19-1781 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed defendant's 240 month sentence imposed after he pleaded guilty to distributing more than 500 grams of methamphetamine. The court held that the district court did not err by applying a four-level role enhancement for defendant's leadership role in the offense pursuant to USSG 3B1.1(a); the district court did not err by applying a two-level sentencing enhancement for obstruction of justice under USSG 3C1.1; and defendant's below-Guidelines sentence was not substantively unreasonable where the district court considered mitigating factors such as defendant's young age, absent father, minimal education, and lack of criminal history.
Court Description: [Smith, Author, with Benton and Kobes, Circuit Judges Criminal case - Sentencing. No error in imposing a four-level role enhancement under Guidelines Sec. 3B1.1(a) for leadership role in the offense or a two-level enhancement under Guidelines Sec. 3C1.1 for obstruction of justice; defendant's below-guidelines sentence was not substantively unreasonable.
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