United States v. Rodriguez-Reyes

CourtCourt of Appeals for the First Circuit
DecidedJune 10, 2026
Docket23-2037
StatusPublished

This text of United States v. Rodriguez-Reyes (United States v. Rodriguez-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. Rodriguez-Reyes, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

No. 23-2037

UNITED STATES OF AMERICA,

Appellee,

v.

JERRY OMAR RODRÍGUEZ-REYES, a/k/a Quiri,

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, Thompson and Aframe, Circuit Judges.

María S. Ramírez-Becerra for appellant. Jeniffer Vélez-Pérez, with whom W. Stephen Muldrow, United States Attorney; Mariana E. Bauzá-Almonte, Assistant United States Attorney, Chief, Appellate Division; and Thomas F. Klumper, Assistant United States Attorney, Senior Appellate Counsel, were on brief, for appellee.

June 10, 2026 THOMPSON, Circuit Judge. Thirteen years after we first

upheld Jerry Omar Rodríguez-Reyes's life sentence following jury

convictions arising from his leadership in a murderous

drug-dealing conspiracy, see United States v. Rodríguez-Reyes

(Rodríguez I), 714 F.3d 1, 17 (1st Cir. 2013), he's before us

again. This time, Rodríguez (whose name we shorten based on

Spanish naming customs) appeals the district court's denial of his

motion to reduce his sentence under the First Step Act. As we'll

explain shortly, we affirm.

I

It all started more than twenty years ago at La Recta,

a section of San Juan's Nemesio R. Canales public housing project.1

Rodríguez I, 714 F.3d at 4. Local kingpin Melvin Méndez-Roldán

ran the crack cocaine business there, and he "charged a monthly

rent to other drug owners who wanted to sell marijuana" at that

same spot. Id. (cleaned up). And while Méndez (who "regularly

patrolled La Recta with firearms" and "frequently used violence,

including lethal violence" to maintain control of his fiefdom) was

arrested in 2003, he still ran the show from his prison cell for

a while. Id. at 4-5.

1 We set the stage with the facts and history from our first opinion on Rodríguez, which itself draws from a jury verdict we upheld as evidentiarily sufficient. See Rodríguez I, 714 F.3d at 8.

- 2 - Enter stage left Rodríguez. In 2004, he began selling

marijuana (about a pound every couple of days) throughout La Recta

and carrying a gun while he did so. Id. at 5. And after Méndez's

arrest, Rodríguez and some fellow dealers sought to protect and

even expand their business, largely through violence. Id.

That campaign culminated in two especially disturbing

events. First was a drive-by-shooting where Rodríguez (alongside

four others) took a stolen SUV and some heavy-duty guns (like

AK-47s) to a rival dealer's spot and opened fire -- killing three

people. Id. Second was the cold-blooded murder of another drug

dealer, Agustín. Id. at 5-6. One day, after a compatriot of

Rodríguez (Héctor González-Suárez) greeted Agustín with an

embrace, Rodríguez shot Agustín in the back of the head. Id. at

6. Rodríguez and González continued to shoot Agustín once he hit

the ground, and he succumbed to the gunshot wounds. Id.

For these acts (and others), Rodríguez was arrested and

charged with several crimes. Id. We'll spare the finer procedural

details and just say that a jury ultimately convicted him and other

dealers (including Méndez and González) of two charges. Id. Count

One was conspiracy to possess with intent to distribute both

marijuana and over 50 grams of crack cocaine (contra 21 U.S.C.

§§ 841 and 860), and Count Two was conspiracy to possess and use

(among other verbs) firearms in the furtherance of/during and in

- 3 - relation to a drug trafficking crime (contra 18 U.S.C.

§ 924(c)(1)(A) and (o)). See Rodríguez I, 714 F.3d at 6.

Then came the sentencing. In calculating Rodríguez's

recommended sentencing range under the United States Sentencing

Guidelines (a.k.a "U.S.S.G." or just "the Guidelines"), the

district court used the "murder cross-reference" guideline (found

at U.S.S.G. § 2D1.1(d)(1)) to determine that the base offense level

for Count One was 43.2 See Rodríguez I, 714 F.3d at 15. Two

enhancements (for leadership and using a minor in the commission

of the offense) pushed the offense level to 47 -- literally off

the sentencing grid -- but it was ultimately treated as 43 anyway,

because that (combined with his criminal history category of I)

already provided a recommended sentence of life imprisonment. Id.

at 15. And the court followed the Guidelines' lead, because it

gave Rodríguez a life sentence for Count One and another ten years

to be served consecutively for Count Two. Id. at 4, 16.

2 As we explained in Rodríguez I, 714 F.3d at 6: This cross-reference provides that, for a drug trafficking crime, "[i]f a victim was killed under circumstances that would constitute murder under 18 U.S.C. § 1111 had such killing taken place within the territorial or maritime jurisdiction of the United States," then the court should "apply § 2A1.1 (First Degree Murder) or § 2A1.2 (Second Degree Murder), as appropriate, if the resulting offense level is greater than that determined under" the drug trafficking guideline. U.S.S.G. § 2D1.1(d)(1).

- 4 - On his first trip to the First Circuit, Rodríguez

challenged the sufficiency of the evidence, as well as the

procedural and substantive reasonableness of his sentence. See

generally id. We affirmed across the board. Id. at 8 (sufficiency

of the evidence); id. at 14-16 (sentencing).

II

Fast forward more than a decade, to October 2023.3 That

month, Rodríguez (through counsel) moved to reduce his sentence

via the First Step Act.

Before we go on further about Rodríguez's case, a word

about that 2018 act of Congress. It "authorizes district courts

to reduce the prison sentences of defendants convicted of certain

offenses involving crack cocaine." Concepcion v. United States,

597 U.S. 481, 486 (2022).4 To be eligible, the defendant must have

violated " a Federal criminal statute, the statutory penalties for

which were modified by section 2 or 3 of the Fair Sentencing Act

of 2010," and that violation must have been "committed before

August 3, 2010." Pub. L. No. 115-391, § 404, 132 Stat. 5194, 5222

(2018). And if the defendant meets that criteria, the court that

3 We note, but do not detail, how Rodríguez has levied two unsuccessful post-conviction challenges in the meantime. 4 For a more thorough history of the legislative background to this case, see United States v. Fields, 13 F.4th 37, 39 (1st Cir. 2021), cert. granted, judgment vacated, 142 S. Ct. 2899 (2022).

- 5 - imposed the sentence may "impose a reduced sentence as if sections

2 and 3 of the Fair Sentencing Act of 2010 . . . were in effect at

the time the covered offense was committed." Id. But importantly,

there are two limits: the court can't reduce the sentence if it

"was previously imposed or previously reduced in accordance" with

the Fair Sentencing Act or if a defendant has already made a First

Step Act motion that was "denied after a complete review of the

motion on the merits." Id.

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