Rosales-Mireles v. United States

Petitioner Florencio Rosales-Mireles was convicted of illegal reentry into the United States. During sentencing in a federal district court, a presentence report mistakenly double-counted a prior conviction, resulting in a higher criminal history category and a guidelines range of 77 to 96 months of imprisonment rather than the correct 70 to 87 months. The district court imposed a 78-month sentence. Rosales-Mireles did not object at trial. On appeal, the Fifth Circuit acknowledged the error was plain but refused to correct it, holding that the defendant had not shown the error affected his substantial rights under the plain-error test. The U.S. Supreme Court granted certiorari to resolve a circuit split.

In a 7-2 decision authored by Justice Sotomayor, the Supreme Court reversed the Fifth Circuit and remanded the case. The Court held that when a district court makes a plain Guidelines error that leads to a higher range, that error ordinarily affects a defendant’s substantial rights, and the court of appeals should exercise its discretion to correct the error absent countervailing circumstances.

Whether a clear and undisputed miscalculation of a defendant’s Federal Sentencing Guidelines range that resulted in a higher range automatically satisfies the “substantial rights” prong of the plain-error standard under Rule 52(b) of the Federal Rules of Criminal Procedure, thereby warranting appellate correction even without a trial objection.

The ruling reinforced the principle that obvious sentencing guideline errors must be corrected on appeal even when not preserved at trial, safeguarding defendants’ right to fair sentencing. It resolved a longstanding circuit split and provided clear guidance that a miscalculation substantially affecting the advisory range is not merely technical but directly impacts the integrity of judicial proceedings, emphasizing the judiciary’s duty to impose lawful sentences.