United States v. Sambrano

CourtCourt of Appeals for the Ninth Circuit
DecidedMarch 6, 2026
Docket23-3408
StatusUnpublished

This text of United States v. Sambrano (United States v. Sambrano) 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. Sambrano, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAR 6 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 23-3408 D.C. No. Plaintiff - Appellee, 4:21-cr-02281-SHR-JR-4 v. MEMORANDUM* ELIAS SAMBRANO,

Defendant - Appellant.

Appeal from the United States District Court for the District of Arizona Scott H. Rash, District Judge, Presiding

Submitted March 2, 2026** Phoenix, Arizona

Before: CLIFTON, BYBEE, and MILLER, Circuit Judges.

Following a guilty plea, Elias Sambrano was convicted of conspiracy to

possess cocaine with intent to distribute and possession of cocaine with intent to

distribute, in violation of 21 U.S.C. §§ 841 and 846. He was sentenced to 60

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). months of imprisonment, the statutory mandatory minimum, and now appeals his

sentence. We affirm.

1. Sambrano challenges the district court’s finding that he is ineligible for

safety-valve relief under 18 U.S.C. § 3553(f). Section 3553(f) allows the

sentencing court to depart from a mandatory minimum sentence for first-time,

nonviolent drug offenders who played a minor role in the offense and who have

made a good-faith effort to cooperate with the government. See United States v.

Shrestha, 86 F.3d 935, 940 (9th Cir. 1996). The statute prescribes five

requirements for relief; if the defendant fails to establish any one of the five

requirements by a preponderance of the evidence, he is ineligible for safety-valve

relief, and the mandatory minimum will apply. See United States v. Ajugwo, 82

F.3d 925, 929 (9th Cir. 1996).

We review for clear error a district court’s factual finding that a defendant is

ineligible for safety-valve relief. United States v. Mejia-Pimental, 477 F.3d 1100,

1103 (9th Cir. 2007). Under that standard, “a reviewing court must ask ‘whether,

on the entire evidence,’ it is ‘left with the definite and firm conviction that a

mistake has been committed.’” Easley v. Cromartie, 532 U.S. 234, 242 (2001)

(quoting United States v. United States Gypsum Co., 333 U.S. 364, 395 (1948)).

The district court found that Sambrano did not provide a complete and

truthful proffer as required by section 3553(f)(5). To satisfy the truthful-proffer

2 23-3408 requirement, a defendant must “truthfully provide[] to the Government all

information and evidence the defendant has concerning the offense or offenses that

were part of the same course of conduct or of a common scheme or plan.” 18

U.S.C. § 3553(f)(5); accord U.S.S.G. § 5C1.2(a)(5). This “tell all you can tell”

requirement mandates that a defendant disclose “all information at his disposal

which is relevant to the offense,” often including “details concerning other parties

to the crime, such as the source who provided defendant with the drugs and other

persons in the chain of distribution, if known.” Shrestha, 86 F.3d at 939. The

disclosure requirement also applies to uncharged conduct related to the offense of

conviction. United States v. Miller, 151 F.3d 957, 958 (9th Cir. 1998).

The district court did not clearly err in finding that Sambrano was not

entirely forthcoming and truthful. For example, it appears that Sambrano lied when

he told prosecutors that he received no money from the sale of one kilogram of

cocaine on November 2, 2020, for which he was convicted. Sambrano’s defense

attorney came close to conceding at Sambrano’s sentencing hearing that Sambrano

made money off the transaction, explaining that Sambrano “didn’t get any profits

at all,” and “[a]t best, he was going to make a commission.” Additionally, the

government’s wiretap intercepts from November 11, 2020, showed Sambrano

attempting to make a profit in a future sale, so the district court was entitled to

believe that Sambrano had profited from the November 2 sale. In another example

3 23-3408 of Sambrano’s lack of candor, prosecutors confronted Sambrano with a transcript

of an intercepted call in which Sambrano mentioned that his cousin in Santa Ana,

Mexico, was looking to get back into the drug trade. In response to questions about

his cousin’s identity, Sambrano told prosecutors that his cousin did not exist. The

district court was entitled to conclude that Sambrano had not shared everything he

knew.

2. Sambrano also argues that the district court erred in applying a two-level

enhancement under U.S.S.G. § 3B1.1(c) for being an “organizer” and in declining

to apply an additional one-level acceptance-of-responsibility reduction under

U.S.S.G. § 3E1.1(b). Even assuming that the district court erred in its Guidelines

calculations, any error was harmless because “the district court ‘would have

imposed the same sentence absent the errors.’” United States v. Leasure, 319 F.3d

1092, 1098 (9th Cir. 2003) (quoting United States v. Matsumaru, 244 F.3d 1092,

1106 (9th Cir. 2001)); see United States v. Munoz-Camarena, 631 F.3d 1028, 1030

n.5 (9th Cir. 2011) (per curiam). Because Sambrano’s conviction for possession of

cocaine with intent to distribute carried a mandatory minimum five-year sentence,

the district court had no discretion to impose a sentence lower than the one

Sambrano received. See United States v. Thornton, 444 F.3d 1163, 1168 (9th Cir.

2006).

4 23-3408 3. Sambrano argues that the district court committed error at sentencing by

providing insufficient reasoning for its sentencing decision, thereby precluding

meaningful appellate review, and by failing to address inconsistencies between its

Guidelines calculation and the calculation in the presentence report. Because

Sambrano did not make those objections below, we review for plain error only.

United States v. Rangel, 697 F.3d 795, 800–01 (9th Cir. 2012). The plain-error

standard of review dictates that reversal is warranted only where there has been (1)

an error, (2) that is plain, (3) that affects substantial rights, and (4) that “seriously

affect[s] the fairness, integrity or public reputation of judicial proceedings.” United

States v.

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