Molina-Martinez v. United States (14-8913)
Issues
For the purposes of plain-error review, should an appellate court apply a rebuttable presumption of prejudice against a defendant if a misapplication of the United States Sentencing Guidelines (“Sentencing Guidelines”) leads a trial court to rely on an erroneous sentencing range calculation?
In order to be granted relief under Federal Rule of Criminal Procedure Rule 52(b) (“Rule 52(b)”), plain-error review requires that a defendant establish prejudice by proving that the error affected a substantial right. See Brief for Petitioner, Saul Molina-Martinez at 17–19. In this case, the Supreme Court has an opportunity to determine whether an appellate court, applying plain-error review, should presume a rebuttable presumption of prejudice if there is a miscalculation of a defendant’s sentencing range under the United States Sentencing Guidelines (“Sentencing Guidelines”). See id. at i. Molina-Martinez, the petitioner, argues that an erroneous sentencing calculation under the Sentencing Guidelines should result in a rebuttable presumption that the error affected a defendant’s substantial rights. See id. at 15. The United States, the respondent, counters that because the misapplication of the Sentencing Guidelines is a non-structural error, Molina-Martinez retains the burden of showing prejudice. See Brief for Respondent, United States at 15, 24–28. The Court’s decision will potentially impact appellate courts’ application of plain-error review under Rule 52(b) and affect the procedural strategy and substantive rights of criminal trial litigants. See Brief for Petitioner at 45, 48; Brief for Respondent at 45–50.
Questions as Framed for the Court by the Parties
Where an error in the application of the United States Sentencing Guidelines results in the application of the wrong Guideline range to a criminal defendant, should an appellate court presume, for purposes of plain-error review under Federal Rule of Criminal Procedure 52(b), that the error affected the defendant’s substantial rights?
On August 31, 2012, United States Customs and Border Protection agents arrested petitioner Saul Molina-Martinez (“Molina-Martinez”)—a Mexican national with no legal status in the United States—near Sarita, Texas. Brief for Petitioner, Saul Molina-Martinez at 1. The agents determined that five days earlier, on August 26, Molina-Martinez illegally entered the United States without inspection.
Edited by
Additional Resources
- Kelly Knaub, Justices to Hear Deportee’s Appeal of Sentencing Calculation, Law 360 (October 1st, 2015).
- Matthew Bultman, Mexican Man Pushes For Sentencing Change At High Court, Law 360 (November 20, 2015).