United States v. Jose Zapien-Alcala

CourtCourt of Appeals for the Ninth Circuit
DecidedAugust 19, 2024
Docket22-10314
StatusUnpublished

This text of United States v. Jose Zapien-Alcala (United States v. Jose Zapien-Alcala) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth 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. Jose Zapien-Alcala, (9th Cir. 2024).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS AUG 19 2024 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 22-10314

Plaintiff-Appellee, D.C. No. 4:21-cr-02892-JCH-JR-1 v.

JOSE DEL CARMEN ZAPIEN-ALCALA, MEMORANDUM*

Defendant-Appellant.

UNITED STATES OF AMERICA, No. 22-10315

Plaintiff-Appellee, D.C. No. 4:21-cr-50156-JCH-JR-1 v.

JOSE DEL CARMEN ZAPIEN-ALCALA, AKA Jose Del Carmen Zapien, AKA Jose Zapien-Alcala,

Appeal from the United States District Court for the District of Arizona John Charles Hinderaker, District Judge, Presiding

Submitted August 15, 2024**

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. San Francisco, California

Before: GRABER, CALLAHAN, and KOH, Circuit Judges.

In September 2022, Jose del Carmen Zapien-Alcala pleaded guilty to

illegally reentering the United States following deportation, in violation of 8

U.S.C. § 1326(a) and (b)(2). At sentencing, the district court applied two offense-

level enhancements under § 2L1.2(b) of the U.S. Sentencing Guidelines

(“U.S.S.G.”) based on prior offenses for which Zapien-Alcala was sentenced

simultaneously in 2019: (1) a four-level enhancement based on his conviction for

illegal reentry; and (2) an eight-level enhancement based on his conviction for

being a felon in possession of a firearm.1 The district court ultimately calculated

Zapien-Alcala’s guideline range to be 84 to 105 months, applied a 36-month

downward variance, and imposed a 48-month custodial sentence. Zapien-Alcala

timely appealed.2 We have jurisdiction under 28 U.S.C. § 1291, and we affirm.

1. The district court properly applied separate enhancements under U.S.S.G.

** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). 1 The district court applied a third offense-level enhancement under § 2L1.2(b)(2), which is not at issue here. 2 Zapien-Alcala separately appealed his supervised release violation case, No. 22- 10315, but he does not challenge that sentence on appeal. We therefore address only his challenges to the sentence imposed in his criminal case, No. 22-10314.

2 § 2L1.2(b)(1) and (b)(3).3 Application Note 4 to § 2L1.2 provides guidance for

situations in which a defendant’s prior sentences “for an illegal reentry offense and

another felony offense were imposed at the same time and treated as a single

sentence for purposes of calculating the criminal history score.” U.S.S.G. § 2L1.2

cmt. n.4; see United States v. Prien-Pinto, 917 F.3d 1155, 1157 (9th Cir. 2019)

(“[A]n Application Note ‘that interprets or explains a guideline is authoritative

unless it violates the Constitution or a federal statute, or is inconsistent with, or a

plainly erroneous reading of, that guideline.’” (quoting Stinson v. United States,

508 U.S. 36, 38 (1993))). In such circumstances, the sentencing court is directed to

do the following:

[U]se the illegal reentry offense in determining the appropriate enhancement under subsection (b)(1), if it independently would have received criminal history points. In addition, use the prior sentence for the other felony offense in determining the appropriate enhancement under subsection (b)(2) or (b)(3), as appropriate, if it independently would have received criminal history points.

U.S.S.G. § 2L1.2 cmt. n.4. Thus, both enhancements apply as long as each prior

offense “independently would have received criminal history points.” Id. Here,

3 The parties disagree about whether we should apply de novo or plain error review. Because, as Zapien-Alcala concedes, he did not object to the Guidelines calculations, plain error review would typically apply. See Molina-Martinez v. United States, 578 U.S. 189, 194 (2016). However, “[i]t is unnecessary for us to decide the appropriate standard of review to apply” because our conclusion would be the same under either. United States v. Castillo, 69 F.4th 648, 653 (9th Cir. 2023).

3 both of Zapien-Alcala’s 2019 offenses would have independently received criminal

history points under § 4A1.1(a), notwithstanding the single sentence rule. Thus,

both prior offenses properly triggered separate enhancements under § 2L1.2(b).

Zapien-Alcala’s assertion that Application Note 4 should be interpreted to

authorize separate enhancements only where the prior sentences were imposed

consecutively, rather than concurrently (as the 2019 district court did), lacks any

supporting authority. See U.S.S.G. supp. app. C, amend. 802 (2016) (indicating

that the phrase “would have received criminal history points” was intended to

“exclud[e] stale convictions” from triggering the enhancements). Our decision in

United States v. Cuevas-Lopez, 934 F.3d 1056 (9th Cir. 2019), does not support

Zapien-Alcala because, as he acknowledges, Cuevas-Lopez did not address a case

that raised the Application Note 4 scenario. Finally, Zapien-Alcala’s invocation of

the rule of lenity is of no moment because there is no “grievous ambiguity or

uncertainty in the guidelines” here. United States v. D.M., 869 F.3d 1133, 1144

(9th Cir. 2017).

2. The district court did not err by applying the eight-level enhancement

under § 2L1.2(b)(3)(B) for Zapien-Alcala’s 2019 felon in possession offense,

rather than the six-level enhancement under § 2L1.2(b)(3)(C).4 The eight-level

4 The parties again disagree about whether we should apply de novo or plain error review. Again, we need not determine which standard applies because our conclusion would be the same under either. See supra n.3.

4 enhancement applies where the sentence imposed for the defendant’s prior non-

reentry felony offense was “two years or more,” whereas the six-level

enhancement applies where the sentence imposed “exceeded one year and one

month.” U.S.S.G. § 2L1.2(b)(3). Because Zapien-Alcala received a 30-month

sentence for his 2019 felon in possession conviction, the eight-level enhancement

under (b)(3)(B) applied.

Zapien-Alcala’s argument — that the district court should have based the

(b)(3) enhancement on the sentence the 2019 district court “would have imposed”

had his felon in possession offense been sentenced independently — is

unpersuasive. Even if his interpretation were correct and the 2019 district court

had sentenced Zapien-Alcala for the felon in possession offense alone, Zapien-

Alcala concedes that the district court would have started from a guideline range of

27 to 30 months. Thus, to receive the six-level enhancement under (b)(3)(C), the

2019 district court would have had to vary downward to impose a sentence below

24 months. We decline Zapien-Alcala’s invitation to speculate as to how this

might have been accomplished.

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Related

Stinson v. United States
508 U.S. 36 (Supreme Court, 1993)
Molina-Martinez v. United States
578 U.S. 189 (Supreme Court, 2016)
United States v. D.M.
869 F.3d 1133 (Ninth Circuit, 2017)
United States v. David Prien-Pinto
917 F.3d 1155 (Ninth Circuit, 2019)
United States v. Vicente Cuevas-Lopez
934 F.3d 1056 (Ninth Circuit, 2019)
United States v. Roberto Castillo
69 F.4th 648 (Ninth Circuit, 2023)

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United States v. Jose Zapien-Alcala, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-jose-zapien-alcala-ca9-2024.