Appealing the judgment in a criminal case, Jose Amado Pena-Medrano raises an argument that he concedes is foreclosed by United States v. Newson, 515 F.3d 374, 377-78 (5th Cir. 2008), which held that the Government may decline to move for an additional one-point reduction under U.S.S.G. § 3E1.1(b) based on the defendant’s refusal to waive his right to appeal. The appellant’s motion for summary disposition is GRANTED, and the judgment of the district court is AFFIRMED.