State of Minnesota v. Julian Sanchez-Sanchez

CourtCourt of Appeals of Minnesota
DecidedApril 27, 2015
DocketA14-584
StatusUnpublished

This text of State of Minnesota v. Julian Sanchez-Sanchez (State of Minnesota v. Julian Sanchez-Sanchez) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Minnesota v. Julian Sanchez-Sanchez, (Mich. Ct. App. 2015).

Opinion

This opinion will be unpublished and may not be cited except as provided by Minn. Stat. § 480A.08, subd. 3 (2014).

STATE OF MINNESOTA IN COURT OF APPEALS A14-0584

State of Minnesota, Respondent,

vs.

Julian Sanchez-Sanchez, Appellant.

Filed April 27, 2015 Affirmed Smith, Judge Concurring specially, Rodenberg, Judge

Hennepin County District Court File No. 27-CR-13-9468

Lori Swanson, Attorney General, St. Paul, Minnesota; and

Michael O. Freeman, Hennepin County Attorney, Linda M. Freyer, Assistant County Attorney, Minneapolis, Minnesota (for respondent)

Mary F. Moriarty, Hennepin County Public Defender, Peter W. Gorman, Assistant Public Defender, Minneapolis, Minnesota (for appellant)

Considered and decided by Chutich, Presiding Judge; Rodenberg, Judge; and

Smith, Judge. UNPUBLISHED OPINION

SMITH, Judge

We affirm appellant’s sentence because the greater-than-double upward durational

departure is supported by severe aggravating circumstances based on the facts admitted

and evidence in the record.

FACTS

After a lengthy FBI investigation into a methamphetamine distribution network,

the state charged appellant Julian Sanchez-Sanchez with conspiracy to commit a first-

degree controlled substance crime. Sanchez-Sanchez pleaded guilty to the charge and

admitted his participation in the conspiracy.

The state gave notice that it intended to seek an upward sentencing departure

because the offense was a major controlled substance offense, a large number of people

were put at risk by the offense, and the offense involved three or more active participants.

Sanchez-Sanchez waived his right to a sentencing jury.

At a court sentencing trial, the district court concluded that three reasons existed

for an upward departure and made corresponding factual findings. First, the district court

found that the offense was a major controlled substance offense because Sanchez-

Sanchez occupied a high-level position within the distribution network and a high degree

of sophistication and planning was involved. Second, the district court found that the

offense involved three or more active participants because the conspiracy involved at

least 20 people and a “significant number” were active participants. And third, the

district court found that a large number of people were put at risk by the offense because

2 methamphetamine is a “particularly dangerous” neurotoxin and the conspiracy was

distributing the drug in vast amounts. After giving consideration to mitigating factors as

well, the district court sentenced Sanchez-Sanchez to 240 months’ incarceration, an

upward durational departure of 279% from the 86-month guidelines sentence.

DECISION

Sanchez-Sanchez argues that the district court erred in its decision to depart

upwardly from a guidelines sentence for five reasons. We review an upward departure

from a guidelines sentence for an abuse of discretion. Tucker v. State, 799 N.W.2d 583,

585-86 (Minn. 2011). The district court may only depart upwardly from a guidelines

sentence if “substantial and compelling circumstances based on aggravating factors” are

present. Dillon v. State, 781 N.W.2d 588, 595 (Minn. App. 2010) (quotation omitted),

review denied (Minn. July 20, 2010). To impose a sentence that is more than double the

guidelines sentence, there must be severe aggravating circumstances. Id. at 596. We

review de novo “whether a valid reason to depart exists” and whether a departure

reason’s severity justifies a sentence that is more than double the presumptive sentence.

Id. at 598. An upward departure will be reversed if the reasons for departing are

“improper or inadequate” or the record does not support the reasons. Tucker, 799

N.W.2d at 586 (quotation omitted).

A.

Sanchez-Sanchez argues that the district court abused its discretion by sentencing

him to 240 months when his codefendants received shorter sentences. The guidelines are

designed to impose proportionate sentences because “convicted felons similar with

3 respect to relevant sentencing criteria ought to receive similar sanctions.” Minn. Sent.

Guidelines 1 (Supp. 2011). While we acknowledge that many of Sanchez-Sanchez’s

codefendants received shorter sentences, the district court did not impose a

disproportionate sentence or abuse its discretion. First, only one codefendant alleged to

be at the top level of the conspiracy had been sentenced at the time, and he received the

statutory maximum sentence. State v. Ayala-Leyva, 848 N.W.2d 546, 552 (Minn. App.

2014) (reversing the sentence because the sentencing jury did not make proper factual

findings), review granted (Minn. Aug. 5, 2014). Moreover, the sentencing criteria were

not the same due to variations in criminal history scores, mitigating and aggravating

factors, and plea agreements. The district court appropriately considered factors that may

not have been present for the codefendants, including Sanchez-Sanchez’s position in the

hierarchy of the conspiracy and his role in facilitating the interstate movement of drugs

and money. See State v. Starnes, 396 N.W.2d 676, 681 (Minn. App. 1986) (“A defendant

is not entitled to a reduction in his sentence merely because a co-defendant or accomplice

has . . . received a lesser sentence.”).

B.

Next, Sanchez-Sanchez contends that the district court failed to make factual

findings in support of its stated departure reasons. We have held that aggravating factors

must be supported by adequate factual findings. Id. at 557-58. For example, if the

district court departs because the crime is a “major controlled substance crime,” it must

specifically name which of the required circumstances existed. Id. at 558. Here, the

district court departed for a major controlled substance offense and made corresponding

4 findings that Sanchez-Sanchez occupied “a high position within the conspiracy” and that

the offense “involved a high degree of sophistication and planning.” See Minn. Sent.

Guidelines 2.D.2.b.5.e-f (Supp. 2011). The district court properly named two specific

circumstances as required by the guidelines. In addition, the district court found that the

crime involved “at least . . . 20 people” and that “a significant number of those persons”

were active participants to support departing for a conspiracy with three or more active

participants. See Minn. Sent. Guidelines 2.D.2.b.10 (Supp. 2011). Finally, the district

court found that the drugs involved were “particularly dangerous” neurotoxins and that

the amounts at issue put “many thousands of people in danger” to support departing on

the basis of the number of people at risk. See State v. Ford, 539 N.W.2d 214, 230 (Minn.

1995) (including conduct that “put a number of people at risk” among reasons to justify

departure). Therefore, each departure reason is supported by sufficient factual findings.

C.

Sanchez-Sanchez also argues that the district court’s decision “was based

exclusively upon hearsay.” Because Sanchez-Sanchez did not object at trial on the basis

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Related

Blakely v. Washington
542 U.S. 296 (Supreme Court, 2004)
State v. Rodriguez
754 N.W.2d 672 (Supreme Court of Minnesota, 2008)
Taylor v. State
670 N.W.2d 584 (Supreme Court of Minnesota, 2003)
Dillon v. State
781 N.W.2d 588 (Court of Appeals of Minnesota, 2010)
State v. Ramey
721 N.W.2d 294 (Supreme Court of Minnesota, 2006)
State v. Edwards
774 N.W.2d 596 (Supreme Court of Minnesota, 2009)
State v. McIntosh
641 N.W.2d 3 (Supreme Court of Minnesota, 2002)
State v. Griller
583 N.W.2d 736 (Supreme Court of Minnesota, 1998)
State v. Jackson
749 N.W.2d 353 (Supreme Court of Minnesota, 2008)
State v. Geller
665 N.W.2d 514 (Supreme Court of Minnesota, 2003)
State v. Starnes
396 N.W.2d 676 (Court of Appeals of Minnesota, 1986)
State v. Leja
684 N.W.2d 442 (Supreme Court of Minnesota, 2004)
State v. Kindem
313 N.W.2d 6 (Supreme Court of Minnesota, 1981)
State v. Ford
539 N.W.2d 214 (Supreme Court of Minnesota, 1995)
State v. Spain
590 N.W.2d 85 (Supreme Court of Minnesota, 1999)
State of Minnesota v. Andrew Will Alexander
855 N.W.2d 340 (Court of Appeals of Minnesota, 2014)
State v. Brown
792 N.W.2d 815 (Supreme Court of Minnesota, 2011)
Tucker v. State
799 N.W.2d 583 (Supreme Court of Minnesota, 2011)
Wells v. State
839 N.W.2d 775 (Court of Appeals of Minnesota, 2013)
State v. Ayala-Leyva
848 N.W.2d 546 (Court of Appeals of Minnesota, 2014)

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