United States v. Feliciano-Candelario

128 F.4th 5
CourtCourt of Appeals for the First Circuit
DecidedFebruary 10, 2025
Docket22-1879
StatusPublished
Cited by3 cases

This text of 128 F.4th 5 (United States v. Feliciano-Candelario) 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. Feliciano-Candelario, 128 F.4th 5 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 22-1879

UNITED STATES OF AMERICA,

Appellee,

v.

JESÚS ABDIEL FELICIANO-CANDELARIO,

Defendant, Appellant.

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

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

Before

Barron, Chief Judge, Gelpí and Montecalvo, Circuit Judges.

Jessica Ellen Earl, Assistant Federal Public Defender, with whom Alejandra Bird-López, Assistant Federal Public Defender, Héctor L. Ramos-Vega, Interim Federal Public Defender, Rachel Brill, Federal Public Defender, and Franco L. Pérez-Redondo, Assistant Federal Public Defender, Supervisor, Appeals Section, were on brief, for appellant.

Julia M. Meconiates, Assistant United States Attorney, with whom W. Stephen Muldrow, United States Attorney, and Mariana E. Bauzá-Almonte, Assistant United States Attorney, Chief, Appellate Division, were on brief, for appellee. February 10, 2025 MONTECALVO, Circuit Judge. Jesús Abdiel

Feliciano-Candelario was indicted on five federal counts stemming

from three separate armed robberies. Pursuant to a plea agreement,

Feliciano pled guilty and was convicted on four of those counts;

the fifth count was dismissed. Under that plea agreement,

Feliciano and the government jointly recommended a sentence of 130

months, which was below the calculated United States Sentencing

Guidelines ("Guidelines") range of 157 to 181 months. The district

court sentenced Feliciano to 181 months.

Feliciano now challenges that sentence on several

grounds, arguing that (1) the district court incorrectly applied

a sentencing enhancement for otherwise using, not brandishing, a

knife during a carjacking; (2) the government breached the plea

agreement by failing to advocate for its terms; (3) the district

court applied community factors impermissibly to enhance his

sentence; and (4) the district court was impermissibly influenced

by a mistaken belief that it could have carried out a piecemeal

sentencing process had Feliciano gone to trial on all counts. We

agree with Feliciano that the district court improperly concluded

that Feliciano otherwise used the knife, not brandished it, and so

vacate his sentence on the carjacking count and remand the case

for further proceedings regarding that enhancement. On all other

grounds, we affirm.

- 3 - I. Background1

A. The Underlying Robberies

This case has its genesis in three armed robberies which

took place in 2019 and 2020, resulting in a single five-count

indictment. We summarize each robbery below, along with the

associated counts.

1. July 2019 Robbery of Battery Delivery Driver

On July 24, 2019, Feliciano and an unnamed accomplice

robbed a delivery driver while he was delivering a shipment of

batteries. Feliciano had a pistol in his waistband and

"brandish[ed]" the firearm to gain access to the driver's truck

and to keep the driver at bay while Feliciano's accomplice removed

the batteries from the truck.

For this robbery, Feliciano was charged with robbery in

violation of the Hobbs Act, 18 U.S.C. § 1951 (Count I of the

indictment), and one count of using, carrying, and brandishing a

firearm during a violent crime, 18 U.S.C. § 924(c)(1)(A)(ii)

(Count II).

1 Because Feliciano pled guilty, we draw these facts from the undisputed portions of the United States Probation Office's ("Probation") presentence investigation report ("PSR"), the transcripts of the status conference and the sentencing hearing, and the plea agreement. See United States v. Ford, 73 F.4th 57, 59 (1st Cir. 2023) (citing United States v. Rivera, 51 F.4th 47, 49 (1st Cir. 2022)).

- 4 - 2. August 2019 Carjacking of Couple

On August 19, 2019, Feliciano robbed and carjacked a

couple, a man and a woman, in front of their home. While the man

got out of the car to open a gate, Feliciano approached the woman

and displayed a knife, saying, "look what I have here." The woman

surrendered her purse to Feliciano. Feliciano then demanded the

car keys as well. The man became aware of what was happening and

ran towards the car, telling Feliciano that they would not be

handing over the keys. The man fell down; as he was getting up,

he saw Feliciano, who "raised the knife and threatened to kill

them if they did not give him the keys to the vehicle."2 The man

threw the keys; Feliciano took them and drove off in the car.

For this carjacking, Feliciano was charged with

carjacking in violation of 18 U.S.C. § 2119(1) (Count III).

3. September 2020 Robbery of Gas Station

On September 20, 2020, Feliciano and two unnamed

accomplices robbed a gas station. Feliciano pointed a firearm at

an employee and demanded that the employee open the register and

then lie down on the ground. Feliciano and his accomplices then

seized money, cigarettes, and rolling paper.

2 The parties' joint stipulation of facts describes Feliciano's threat as being directed towards the man, stating that Feliciano "raised the knife and threatened to kill [the man]."

- 5 - Feliciano's charges for this robbery mirrored those for

the delivery driver robbery: one Hobbs Act robbery count (Count

IV), and one count of using, carrying, and brandishing a firearm

during a violent crime (Count V).

B. Federal Criminal Proceedings Against Feliciano

On March 30, 2021, as detailed above, Feliciano was

indicted on five counts for the three armed robberies.

Feliciano moved to sever the charges into three separate

trials, with each trial corresponding to each robbery, contending

that evidence relating to one robbery would otherwise spill over

and unduly prejudice him regarding the others. The district court

granted the motion. At a subsequent status conference, the

district court observed that, assuming each robbery was tried and

each trial resulted in a conviction, it might be able to either

sentence Feliciano at the end of each trial or sentence him once,

for all of the counts, upon the conclusion of all three trials.

The court also stated that it "may be wrong" about whether it could

sentence Feliciano in this way.

This prompted Feliciano to move for another hearing to

clarify the contemplated sentencing procedure and his potential

exposure. The court granted the motion and held a hearing but

noted during the hearing that it still had not decided on a

sentencing procedure and would not decide "until after the first

trial probably."

- 6 - A few weeks later, Feliciano and the government reached

a plea agreement. Under its terms, Feliciano pled guilty to all

but one of the counts. The parties agreed that Count V (using,

carrying, and brandishing a firearm stemming from the 2020 gas

station robbery) would be dismissed. The parties also agreed that

a three-level sentencing enhancement for "brandishing a dangerous

weapon" under U.S.S.G.

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