U.S. v. Castaneda

Dist. Ct. erred in sentencing defendant to 12-year term on drug conspiracy and attempted drug distribution charges. Record showed that, although both charges had statutory mandatory minimum sentence of 10 years, defendant also qualified for safety valve treatment under section 3553(f) of USSG, which obligated Dist. Ct. to sentence defendant without regard to any statutory minimums. As such, defendant was entitled to new sentencing hearing, where record showed that Dist. Ct. did not appreciate that defendant qualified for safety valve treatment with respect to his sentence. Moreover, government improperly represented during sentencing hearing that safety valve’s application was permissive rather than mandatory.