United States v. Guzman

The Eighth Circuit affirmed Defendants Guzman and Morales' conviction for drug-related offenses. The court affirmed the district court's denial of defendants' motion to suppress evidence obtained from the stop of a minivan where defendants were specifically identified as the occupants of the van before the stop and thus the officers had probable cause to believe that they were in the vehicle.The court affirmed Guzman's sentence and held that Dean v. United States, 137 S. Ct. 1170 (2017), was inapplicable in this case and the district court did not have to vary his sentence downward. The court rejected Morales' claims of evidentiary error and held that his sentence was not procedurally unreasonable. The district court correctly determined that Morales' base offense level, and did not err by imposing sentencing enhancements under USSG 2D1.1(b)(1) for possession of a dangerous weapon, USSG 2D1.1(b)(2) for making a credible threat of violence; and USSG 3B1.1(a) for being an organizer or leader of a criminal activity that involved five or more participants. View "United States v. Guzman" on Justia Law