United States v. Fuentes-Echevarria

Police officers stopped Raymond Fuentes-Echevarria's (defendant's) car when they noticed him driving the car in reverse, in the middle of a street. Fuentes-Echevarria immediately fled but was later arrested after the officers found a machine gun, an automatic pistol, and a large quantity of ammunition hidden in the car's secret compartment. The federal government (plaintiff) prosecuted Fuentes-Echevarria for illegally possessing the machine gun, and he pleaded guilty. Based on Fuentes-Echevarria's limited criminal record and his acceptance of responsibility for his crime, the federal sentencing guidelines recommended a sentencing range of between 21 and 27 months' imprisonment, but the government requested a 60-month sentence. Before imposing a sentence of 48 months' imprisonment and 36 months' supervised release, the federal district court judge commented that he wanted to help shrink the "arsenal of weapons" in Fuentes-Echevarria's violent and drug-infested neighborhood. The judge added that other factors also played a role in his sentencing decision, for example, Fuentes-Echevarria's flight from the police and concealment of his firearms stash. The judge explained that all these factors identified Fuentes-Echevarria's crime as more than a routine heartland matter, and warranted an upward variance from the sentencing guidelines. On appeal to the First Circuit Court of Appeals, Fuentes-Echevarria argued that the judge gave too much attention to the need for general deterrence in Fuentes-Echevarria's neighborhood, and not enough to personal factors that weighed in his favor.