United States v. Rosario-Ramos

138 F.4th 677
CourtCourt of Appeals for the First Circuit
DecidedMay 28, 2025
Docket21-1507
StatusPublished

This text of 138 F.4th 677 (United States v. Rosario-Ramos) 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. Rosario-Ramos, 138 F.4th 677 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 21-1507

UNITED STATES OF AMERICA,

Appellee,

v.

ELIEZER ROSARIO-RAMOS,

Defendant, Appellant.

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

[Hon. Aida M. Delgado-Colón, U.S. District Judge]

Before

Barron, Chief Judge, Kayatta and Aframe, Circuit Judges.

José R. Olmo-Rodríguez for appellant. Gregory B. Conner, Assistant U.S. Attorney, with whom W. Stephen Muldrow, U.S. Attorney, and Mariana E. Bauzá-Almonte, Assistant U.S. Attorney, Chief, Appellate Division, were on brief, for appellee.

May 28, 2025 KAYATTA, Circuit Judge. After assaulting and robbing an

elderly woman, Eliezer Rosario-Ramos and his brother were indicted

for carjacking resulting in serious bodily injury and bank larceny.

Rosario-Ramos pled guilty to the carjacking offense and proposed

an upwardly variant sentence of fifteen years. Citing, among other

considerations, the brutal nature of the attack and the death of

the victim Zulma Lebrón-Serrano soon after, the district court

sentenced Rosario-Ramos to twenty-three years. Rosario-Ramos now

appeals, asserting a host of procedural and substantive defects

with his sentence. We affirm.

I.

In August 2018, Rosario-Ramos and his grandfather were

at the home of seventy-seven-year-old Lebrón-Serrano to perform

some paid work. During the job, Lebrón-Serrano gave Rosario-Ramos

her debit card and personal identification number (PIN) to buy

himself and his grandfather breakfast. When purchasing the food,

Rosario-Ramos ran Lebrón-Serrano's account balance, saw that it

totaled over $18,000, and decided to rob her.

Rosario-Ramos recruited his brother Orlando Martínez-

Ramos to participate in the robbery. On the evening of August 15,

2018, the two brothers broke into Lebrón-Serrano's home,

blindfolded and gagged her, beat her with a frying pan, and stole

her money, some of her valuables, and her car. They then went on

an extended shopping spree before being arrested by the police for

- 2 - driving a stolen vehicle. Nine days after the attack, Lebrón-

Serrano died. According to the medical autopsy report, the causes

of her death were acute pulmonary edema, atherosclerotic and

hypertensive cardiac disease, uncontrolled arterial hypertension,

and uncontrolled diabetes mellitus. The autopsy report also lists

facial and bodily trauma as "contributory" factors.

The following month, a federal grand jury returned a

two-count indictment charging carjacking resulting in serious

bodily injury and bank larceny. Rosario-Ramos pled guilty to the

carjacking offense. The parties stipulated that the appropriate

offense level for Rosario-Ramos translated to a sentencing range

under the U.S. Federal Sentencing Guidelines of 11.25 to 14 years.

But as part of his plea deal, Rosario-Ramos agreed that an upward

variance was appropriate "[a]fter due consideration of the

relevant factors enumerated in 18 U.S.C. § 3553(a) and the victim's

death within nine days of the carjacking and attack." Rosario-

Ramos proposed a sentence of fifteen years, and the government

proposed a sentence of sixteen years.

The U.S. Probation Office issued a presentence

investigation report (PSR), in which it concluded that the

§ 2B3.1(c)(1) murder cross-reference should apply, thereby

increasing the Guidelines-recommended sentence to life

imprisonment. See U.S.S.G. §§ 2B3.1(c)(1), 2A1.1. But

recognizing that the maximum term of imprisonment for carjacking

- 3 - resulting in serious bodily injury is twenty-five years, see 18

U.S.C. § 2119(2), the Probation Office recommended a sentence of

twenty-five years. In his written response, Rosario-Ramos

contested, among other things, the Probation Office's conclusion

that the murder cross-reference should apply.

At sentencing, the district court declined to apply the

murder cross-reference, citing the government's stance that it

would be "difficult to establish a . . . direct causal

relationship between the beating and [Lebrón-Serrano's death]."

The district court noted, however, that the autopsy report made it

"clear that the assault, and robbery, and the beating of the victim

had direct consequences and exacerbated what already was a chronic

condition." The district court found that the attack carried out

by Rosario-Ramos and his brother contributed to Lebrón-Serrano's

death. Thus, the court sentenced Rosario-Ramos to twenty-three

years of imprisonment.

Rosario-Ramos now appeals. He argues that the district

court impermissibly relied during sentencing on the assumption

that Rosario-Ramos's attack on Lebrón-Serrano contributed to her

death; that the district court impermissibly imposed an upward

variance based on aggravating factors already contemplated by the

Guidelines; and that his sentence is substantively unreasonable

because it is substantially higher than his brother's and exceeds

- 4 - both the Guidelines sentencing range and the already upwardly

variant sentences put forth by both parties.1

We address these arguments seriatim and conclude that

Rosario-Ramos's sentence is procedurally and substantively sound.

As such, we affirm the district court's judgment.

II.

Appellate review of sentencing challenges "involves a

two-step pavane." United States v. Rivera-Morales, 961 F.3d 1, 15

(1st Cir. 2020). First, we evaluate the procedural soundness of

the sentence; if we find no procedural error, we go on to weigh

the sentence's substantive reasonableness. Id. "A sentence is

procedurally sound so long as the district court did not commit a

procedural error in arriving at the sentence." United States v.

Rivera-Moreno, 613 F.3d 1, 8 (1st Cir. 2010); see also Gall v.

United States, 552 U.S. 38, 51 (2007) (listing examples of

procedural errors). And a sentence is substantively reasonable so

long as it reflects "a plausible sentencing rationale and a

defensible result." United States v. Martin, 520 F.3d 87, 96 (1st

Cir. 2008).

1 Rosario-Ramos also contends that his sentence is so excessive as to constitute cruel and unusual punishment in violation of the Eighth Amendment. But this challenge consists of a single conclusory sentence. As such, we deem it waived for underdevelopment and do not consider it further. See United States v. Zannino, 895 F.2d 1, 17 (1st Cir. 1990).

- 5 - A.

We first address Rosario-Ramos's contention that his

sentence is procedurally unfair because the district court

improperly determined that the attack causally contributed to

Lebrón-Serrano's death. We review the district court's rejection

of this preserved objection for abuse of discretion. See United

States v. Vargas-Martinez, 15 F.4th 91, 98 (1st Cir. 2021). Within

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