United States v. Miguel Lolo

CourtCourt of Appeals for the Eleventh Circuit
DecidedMay 20, 2020
Docket19-12123
StatusUnpublished

This text of United States v. Miguel Lolo (United States v. Miguel Lolo) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh 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. Miguel Lolo, (11th Cir. 2020).

Opinion

Case: 19-12123 Date Filed: 05/20/2020 Page: 1 of 6

[DO NOT PUBLISH]

IN THE UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT ________________________

No. 19-12123 Non-Argument Calendar ________________________

D.C. Docket No. 8:18-cr-00133-EAK-AEP-1

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

versus

MIGUEL LOLO,

Defendant - Appellant.

________________________

Appeal from the United States District Court for the Middle District of Florida ________________________

(May 20, 2020)

Before WILSON, LUCK and MARCUS, Circuit Judges.

PER CURIAM:

Miguel Lolo appeals his 60-month above-guidelines sentence imposed for

cyberstalking, in violation of 18 U.S.C. § 2261A(2)(B) and 2261(b), and making

interstate threats, in violation of 18 U.S.C. § 875(c). On appeal, Lolo argues that his Case: 19-12123 Date Filed: 05/20/2020 Page: 2 of 6

sentence was procedurally unreasonable because the district court gave, as the

primary reason for varying upward, Lolo’s need for mental health treatment. The

government agrees that the district court committed plain error in doing so. After

careful review, we vacate and remand for resentencing.

We usually review sentences imposed by a district court for “reasonableness,”

which “merely asks whether the [] court abused its discretion.” United States v.

Pugh, 515 F.3d 1179, 1189 (11th Cir. 2008) (quotation omitted). However, if a party

does not object to the procedural reasonableness of a sentence before the district

court, we review for plain error. United States v. Vandergrift, 754 F.3d 1303, 1307

(11th Cir. 2014). “[T]he burden of establishing entitlement to relief for plain error

is on the defendant claiming it.” United States v. Dominguez Benitez, 542 U.S. 74,

82 (2004). The defendant must show that: (1) an error occurred; (2) the error was

plain; and (3) the error affects his substantial rights. Rosales-Mireles v. United

States, 138 S. Ct. 1897, 1904-05 (2018). When these three factors are met, we should

exercise our discretion and correct the error if it seriously affects the fairness,

integrity, or public reputation of judicial proceedings. Id. at 1905.

An error is plain if controlling precedent from the Supreme Court or this Court

establishes that an error occurred. United States v. Ramirez-Flores, 743 F.3d 816,

822 (11th Cir. 2014). An error affects substantial rights only if it is prejudicial,

meaning that it must have affected the outcome of the district court proceedings.

2 Case: 19-12123 Date Filed: 05/20/2020 Page: 3 of 6

United States v. Olano, 507 U.S. 725, 734 (1993). The defendant must establish a

reasonable probability of a different result, i.e., a probability sufficient to undermine

confidence in the outcome. United States v. Rodriguez, 398 F.3d 1291, 1299 (11th

Cir. 2005). The defendant cannot show that his substantial rights have been affected

if we would have to speculate as to the effect of an error on the result. Id. at 1301.

The fourth prong of plain error review is to be applied on a case-specific and

fact-intensive basis. Puckett v. United States, 556 U.S. 129, 142 (2009). However,

the Supreme Court has said that the risk of unnecessary deprivation of liberty

particularly undermines the fairness, integrity, or public reputation of judicial

proceedings in the context of a plain guidelines error. Rosales-Mireles, 138 S. Ct.

at 1908. This means that a failure to correct a plain guidelines error that affects a

defendant’s substantial rights will, in the ordinary case, seriously affect the fairness,

integrity, and public reputation of judicial proceedings. Id. at 1911. A court’s failure

to consider the 18 U.S.C. § 3553(a) factors constitutes significant procedural error,

as does a court’s consideration of an improper factor. Vandergrift, 754 F.3d at 1308.

We have held that a faulty sentencing enhancement ordinarily will satisfy the fourth

plain-error prong, at least when the other three factors are met, and, as a remedy,

have vacated the defendant’s sentence and remanded for resentencing. United States

v. Bankston, 945 F.3d 1316, 1320 (11th Cir. 2019).

3 Case: 19-12123 Date Filed: 05/20/2020 Page: 4 of 6

In Tapia v. United States, the Supreme Court instructed that federal courts

may not consider a defendant’s rehabilitative needs when imposing or lengthening

a prison sentence. 564 U.S. 319, 328-29 (2011). We’ve applied this directive and

held that a district court erred in considering a defendant’s rehabilitative needs at

sentencing. Vandergrift, 754 F.3d at 1310-11. However, we’ve also held that a

defendant cannot show that his substantial rights were affected if his rehabilitative

needs constituted only a minor subset of the district court’s reasoning. United States

v. Alberts, 859 F.3d 979, 986 (11th Cir. 2017). Accordingly, we’ve affirmed a

sentence as procedurally reasonable where the sentencing transcript showed that

rehabilitation was merely an ancillary concern. Id.

We note, at the outset, that we are not required to accept the government’s

concession of error when the law and record do not justify it. United States v.

Linville, 228 F.3d 1330, 1331 n.2 (11th Cir. 2000). Here, however, based on our

own review of the record, we agree with the government that the district court

committed plain error in sentencing Lolo. As the record reflects, the district court

repeatedly considered rehabilitation throughout its sentencing decision, even

beginning and ending its discussion with it. By doing so, the district court imposed

a sentence in direct contravention of controlling precedent from both the Supreme

Court and this Court, Tapia, 564 U.S. at 328-29; Vandergrift, 754 F.3d at 1310, and,

therefore, committed plain error by imposing a procedurally unreasonable sentence.

4 Case: 19-12123 Date Filed: 05/20/2020 Page: 5 of 6

Moreover, the error affected Lolo’s substantial rights. Rather than

constituting a mere ancillary concern, the record reveals that rehabilitation was the

district court’s main reason for varying upward. Lolo’s mental health was the first

thing the district court discussed in explaining its sentence, and it expressly referred

to Lolo’s rehabilitative needs as its starting point. The court continued to emphasize

rehabilitation throughout its discussion, unprompted by either party, as it asked

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Related

United States v. Pugh
515 F.3d 1179 (Eleventh Circuit, 2008)
United States v. Olano
507 U.S. 725 (Supreme Court, 1993)
United States v. Dominguez Benitez
542 U.S. 74 (Supreme Court, 2004)
Puckett v. United States
556 U.S. 129 (Supreme Court, 2009)
Tapia v. United States
131 S. Ct. 2382 (Supreme Court, 2011)
United States v. Lazaro Ramirez-Flores
743 F.3d 816 (Eleventh Circuit, 2014)
United States v. Walter Henry Vandergrift, Jr.
754 F.3d 1303 (Eleventh Circuit, 2014)
United States v. David Ryan Alberts
859 F.3d 979 (Eleventh Circuit, 2017)
Rosales-Mireles v. United States
585 U.S. 129 (Supreme Court, 2018)
United States v. Donald John Bankston, III
945 F.3d 1316 (Eleventh Circuit, 2019)
United States v. Rodriguez
398 F.3d 1291 (Eleventh Circuit, 2005)

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