United States v. Colorado-Castillo

CourtCourt of Appeals for the Second Circuit
DecidedApril 16, 2025
Docket24-1669
StatusUnpublished

This text of United States v. Colorado-Castillo (United States v. Colorado-Castillo) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Colorado-Castillo, (2d Cir. 2025).

Opinion

24-1669 United States v. Colorado-Castillo

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 16th day of April, two thousand twenty-five.

Present: DEBRA ANN LIVINGSTON, Chief Judge, RAYMOND J. LOHIER, JR., MYRNA PÉREZ, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Appellee,

v. 24-1669

ERICK DE JESUS COLORADO-CASTILLO, A/K/A ERICK DEJESUS COLORADO CASTILLO,

Defendant-Appellant. _____________________________________

For Appellee: JOSHUA ROTHENBERG, Assistant United States Attorney, on behalf of Carla B. Freedman, United States Attorney for the Northern District of New York, Syracuse, NY.

For Defendant- Appellant: MOLLY K. CORBETT, Assistant Federal Public Defender, Office of the Federal Public Defender, Northern District of New York, Albany, NY.

1 Appeal from a judgment of the United States District Court for the Northern District of

New York (Sannes, C.J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

Defendant-Appellant Erick De Jesus Colorado-Castillo (“Colorado-Castillo”) appeals

from a judgment of the United States District Court for the Northern District of New York (Sannes,

C.J.), entered on June 20, 2024, upon a guilty plea, sentencing him to a 70-month term of

imprisonment and a 3-year term of supervised release for knowingly and intentionally possessing

with intent to distribute a controlled substance, in violation of 21 U.S.C. § 841(a)(1). In doing so,

the district court denied Colorado-Castillo’s request for a minor or mitigating role reduction

pursuant to U.S.S.G. § 3B1.2. On appeal, Colorado-Castillo argues that (1) he should have

received a minor or mitigating role reduction; and (2) his sentence is substantively unreasonable.

Neither argument is availing. We assume the parties’ familiarity with the underlying facts, the

procedural history of the case, and the issues on appeal.

I. Minor/Mitigating Role Adjustment

The crux of Colorado-Castillo’s first challenge is that the district court failed adequately to

assess Colorado-Castillo’s role, relative to his co-conspirators, in the broader drug scheme in

which he participated. 1 Appellant’s Br. 18. We disagree.

1 Colorado-Castillo also suggests that the district court erred by “rel[ying] on erroneous facts or facts outside the record” but does not elaborate on this argument. Appellant’s Br. 18. Accordingly, we consider this argument to be abandoned. See Norton v. Sam’s Club, 145 F.3d 114, 117 (2d Cir. 1998) (“Issues not sufficiently argued in the briefs are considered waived and normally will not be addressed on appeal.”). Moreover, to the extent Colorado-Castillo raises a procedural unreasonableness argument, see Appellant’s Br. 18 (arguing that the district court “[f]ailed to [p]roperly [e]xplain its [s]entence [d]ecision” when assessing whether Colorado-Castillo was entitled to a minor or mitigating role adjustment), this argument is duplicative of his challenge to the district court’s denial of his request for a minor role adjustment.

2 When a defendant’s challenge “go[es] principally to the district court’s underlying factual

findings regarding the Guidelines’ mitigating role adjustment factors, we [apply] the deferential

‘clear error’ standard.” 2 United States v. Wynn, 108 F.4th 73, 81 n.4 (2d Cir. 2024) [hereinafter

Wynn II]. Such is the case here. See, e.g., Appellant’s Br. 22–23 (arguing that “[t]he offense

conduct and context of the text messages demonstrate [that] Mr. Colorado-Castillo was not in

charge, was taking directions from another, was not a trusted member of the scheme, had no

knowledge of the potential or standard payment, and was attempting to ingratiate himself or instill

confidence in him”). Clear error exists when the court has “the definite and firm conviction that

a mistake has been committed.” United States v. Osuba, 67 F.4th 56, 65 (2d Cir. 2023), cert.

denied, 144 S. Ct. 577 (2024). “Where there are two permissible views of the evidence, the

factfinder’s choice between them cannot be clearly erroneous.” United States v. Salim, 549 F.3d

67, 74 (2d Cir. 2008).

“[T]he critical question for a mitigating role reduction” is a defendant’s “relative role in

th[e] criminal enterprise.” Wynn II, 108 F.4th at 83. “The district court’s determination ‘depends

upon the nature of the defendant’s relationship to other participants, the importance of the

defendant’s actions to the success of the venture, and the defendant’s awareness of the nature and

scope of the criminal enterprise.’” Id. at 81 (quoting United States v. Shonubi, 998 F.2d 84, 90 (2d

Cir. 1993)). The commentary to the Guidelines further explains that the application of the

mitigating role adjustment is “based on the totality of the circumstances,” and sets forth a non-

exhaustive list of factors to consider:

2 While the government suggests that Colorado-Castillo may have waived his challenge to the denial of a minor role adjustment, it ultimately “waives [its argument that] Colorado-Castillo[] fail[ed] to preserve” and “asks the Court to review the merits of the district court’s decision for clear error, notwithstanding the failure to preserve, potential waiver, and Colorado-Castillo’s opening brief not addressing either.” Appellee’s Br. 21.

3 (i) the degree to which the defendant understood the scope and structure of the criminal activity;

(ii) the degree to which the defendant participated in planning or organizing the criminal activity;

(iii) the degree to which the defendant exercised decision-making authority or influenced the exercise of decision-making authority;

(iv) the nature and extent of the defendant’s participation in the commission of the criminal activity, including the acts the defendant performed and the responsibility and discretion the defendant had in performing those acts;

(v) the degree to which the defendant stood to benefit from the criminal activity.

U.S.S.G. § 3B1.2 cmt. n.3(C).

Here, the district court did inquire into the “critical question for a mitigating role reduction”

— i.e., Colorado-Castillo’s “relative role in th[e] criminal enterprise.” Wynn II, 108 F.4th at 83.

It determined that Colorado-Castillo “do[es] not appear to be a one-time courier with limited

knowledge of the organization.” App’x 62. In reaching this conclusion, the court relied on

Probation’s assessment, and its own assessment, that Colorado-Castillo (1) had a high degree of

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Related

United States v. Salim
549 F.3d 67 (Second Circuit, 2008)
United States v. Aldeen
792 F.3d 247 (Second Circuit, 2015)
United States v. Ryan
806 F.3d 691 (Second Circuit, 2015)

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