DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
153248P.pdf 07/11/2016 United States v. Juan Leanos
U.S. Court of Appeals Case No: 15-3248
U.S. District Court for the Southern District of Iowa - Des Moines
[PUBLISHED] [Smith, Author, with Loken and Beam, Circuit Judges Criminal
case - Sentencing. No error in denying safety-valve relief; Alleyne does
not apply to safety-valve determinations, and the government did not need
to plead and prove to a jury that defendant possessed a firearm in
connection with the underlying drug offense, the possession of which made
him ineligible for safety-valve sentencing; the court did not err in
finding defendant possessed a firearm in connection with the underlying
drug offense; any error in denying defendant a role reduction was harmless
as a lower guidelines range would not affect the 120-month mandatory
minimum applicable to the case.