United States v. Fargas-Reyes

CourtCourt of Appeals for the First Circuit
DecidedJanuary 10, 2025
Docket23-1503
StatusPublished

This text of United States v. Fargas-Reyes (United States v. Fargas-Reyes) is published on Counsel Stack Legal Research, covering Court of Appeals for the First 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. Fargas-Reyes, (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

Nos. 23-1502 23-1503

UNITED STATES OF AMERICA,

Appellee,

v.

JONATHAN KEMUEL FARGAS-REYES,

Defendant, Appellant.

APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

[Hon. Francisco A. Besosa, U.S. District Judge]

Before Montecalvo, Thompson, and Aframe, Circuit Judges.

Jackson Whetsel, with whom Rachel Brill, Federal Public Defender, Franco L. Pérez-Redondo, Assistant Public Defender, Supervisor, Appellate Section, and Alejandra Bird-López, Assistant Public Defender, were on brief, for appellant. Ethan A. Sachs, with whom W. Stephen Muldrow, United States Attorney, Mariana E. Bauzá-Almonte, Assistant United States Attorney, Appellate Chief, and Maarja T. Luhtaru, Assistant United States Attorney, were on brief, for appellee.

January 10, 2025 THOMPSON, Circuit Judge.

PREFACE

Jonathan Fargas-Reyes is a repeat firearms offender.

Read on to learn more about his brushes with the law and why we

can't vacate his sentences for committing another gun crime and

for violating an earlier supervised release.

HOW THE CASE GOT HERE1

Back in September 2021, Fargas (as we'll now call him,

per Spanish-naming customs) pled guilty to unlawfully possessing

a Glock pistol changed to fire as a machinegun. See 18 U.S.C.

§ 922(o). A federal judge sentenced him to 33 months in prison

plus 3 years of supervised release.2 He started supervised release

in November 2021. But he didn't stay out of trouble for very long.

Jump ahead only a few months, to January 2022. Puerto

Rico police spied Fargas outside a house he shared with girlfriend

1 The major background events are undisputed unless otherwise noted (we simplify the details here rather aggressively, adding more info later as needed for specific issues). 2 Supervised release and the conditions on that release help "criminal defendants and the public alike by facilitating sooner rather than later" the offenders' "re-entry into society." See United States v. Shultz, 733 F.3d 616, 624 (6th Cir. 2013); see also United States v. Siegel, 753 F.3d 705, 708 (7th Cir. 2014) (stating that "[r]educing recidivism is the main purpose of supervised release, though some of the conditions of supervised release are intended to help the released prisoner adjust to life on the outside even if there is no worry that without them he would be likely to commit crimes"). - 2 - Mary Herrera-Cruz (officers had heard he had a stolen Hyundai

Tucson there). He was packing a pistol in his waistband and

holding an AK-47-looking rifle in his right hand. Standing next

to Herrera's Kia Rio, Fargas popped open the hatchback, put the

AK-47 in a duffel bag and the pistol in a backpack, and dropped

them both in the rear area before closing the door.

Herrera then walked over with her two young daughters.

And everyone — Herrera (driver's seat), Fargas (front passenger's

seat), and the girls (back seats) — got in the Kia. Fargas pulled

a ski mask with eyeholes down over his face. Herrera drove off.

The police tried to stop them. But Herrera kept right

on going. Following a short chase, Fargas stuck his arms out the

car's window. Herrera stopped the Kia. And Fargas got out. Not

ready (apparently) to give herself up, Herrera sped away.

After arresting Fargas, the police again raced after

Herrera. Spotting her Kia on the side of the road, officers

watched her fling the duffel bag into some bushes. She then closed

the hatchback, got behind the wheel, and tried again to shake them.

But she hit a barrier and then another vehicle (with the two girls

still seated in the back of the Kia).

The police arrested Herrera too. And their search of

the recovered duffel bag and backpack revealed 2 Glock pistols

modified to fire as machineguns, 1 AK-47 pistol, 1 drum magazine,

- 3 - 6 high-capacity magazines, and 173 rounds of assorted-caliber

ammo.

Indicted federally on firearms-related charges, Fargas

and Herrera signed plea agreements with the government. Fargas —

in February 2023 — pled guilty to illegally possessing firearms

and ammunition as a convicted felon. See 18 U.S.C. § 922(g)(1).

And Herrera — two months earlier, in December 2022 — pled guilty

to aiding and abetting a convicted felon in illegally possessing

firearms and ammunition. See id.; see also 18 U.S.C. § 2.

We'll have plenty to say later about what happened at

sentencing.3 But for now it's enough to note the following. The

3 For anyone needing a refresher on how a federal district judge approaches sentencing, here it is. Using the now-advisory federal sentencing guidelines (Fargas's judge used the 2021 guidelines edition, the one in effect at the time of sentencing), the judge sets the defendant's base offense level — i.e., a point score for a specified offense or group of offenses. The [judge] then make[s] adjustments for any aggravating or mitigating factors in the defendant's case, thus arriving at a total offense level. The [judge] also assign[s] points based on the defendant's criminal history — points that get converted into various criminal history categories, designated by Roman numerals I through VI. Armed with this info, the judge turns to the guidelines's sentencing table. And by plotting the defendant's total offense level along the table's vertical axis and his criminal history category along the table's horizontal axis, the judge ends up with an - 4 - advisory prison range. From there, the judge sees if any departures are called for, considers various sentencing factors [listed in 18 U.S.C. § 3553(a)], and determines what sentence (whether within, above, or below the suggested range) seems appropriate. United States v. Martínez-Benítez, 914 F.3d 1, 2 n.2 (1st Cir. 2019) (citations omitted). As for the § 3553(a) factors, there are seven of them. Factor one is "the nature and circumstances of the offense and the history and characteristics of the defendant." 18 U.S.C. § 3553(a)(1). Factor two is the need for the sentence . . . (A) to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense; (B) to afford adequate deterrence to criminal conduct; (C) to protect the public from further crimes of the defendant; and (D) to provide the defendant with needed educational or vocational training, medical care, or other correctional treatment in the most effective manner. Id. § 3553(a)(2). Factor three is "the kinds of sentences available." Id. § 3553(a)(3). Factor four is the guidelines. Id. § 3553(a)(4). Factor five is "any pertinent policy statement . . . issued by the [s]entencing [c]ommission." Id. § 3553(a)(5). Factor six is "the need to avoid unwarranted sentence disparities." Id. § 3553(a)(6). And factor seven is "the need to provide restitution to any victims." Id. § 3553(a)(7). United States v. Correa-Osorio, 784 F.3d 11, 28 n.24 (1st Cir. 2015); see also Rita v. United States, 551 U.S. 338, 347-48 (2007).

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