United States v. Rafael Madrid-Ojeda
United States v. Rafael Madrid-Ojeda
Opinion
Rafael Madrid-Ojeda (Madrid) appeals the sentence the district court 1 imposed after he pleaded guilty to conspiring to distribute 500 grams or more of a methamphetamine mixture, in violation of 21 U.S.C. §§ 841(a)(1), (b)(1), and 846, and to a criminal forfeiture count. The district court sentenced Madrid to the statutory mandatory minimum of 120 months imprisonment. See 21 U.S.C. § 841(b)(1)(A). Madrid’s counsel has filed a brief under Anders v. California, 386 U.S. 738, 87 *108 S.Ct. 1396, 18 L.Ed.2d 493 (1967), arguing Madrid should have been sentenced below the statutory mandatory minimum term despite his failure to qualify for “safety valve” relief.
The district court did not err in sentencing Madrid to the mandatory minimum, because it is undisputed that he did not meet all the requirements for safety-valve relief. See 18 U.S.C. § 3553(f) (listing factors that allow court to sentence below mandatory minimum); United States v. Chacon, 330 F.3d 1065, 1066 (8th Cir. 2003) (finding district court did not have authority to depart below statutory minimum where government did not file substantial-assistance motion and defendant did not qualify for safety-valve relief). ■
Having carefully reviewed the record under Penson v. Ohio, 488 U.S. 75, 80, 109 S.Ct. 346, 102 L.Ed.2d 300 (1988), we find no nonfrivolous issues. Accordingly, we affirm.
. The Honorable Laurie Smith Camp, United States District Judge for the District of Nebraska.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.