United States v. Caballero
Saul Caballero, who pleaded guilty to two drug conspiracies (heroin and methamphetamine distribution), objected to an aggravating role enhancement under the Sentencing Guidelines, arguing it would increase his mandatory-minimum sentence and thus require a jury finding beyond a reasonable doubt as per Alleyne v. United States. Following a two-day Fatico hearing, the District Court concluded that the government proved by a preponderance of the evidence that Caballero was a manager or supervisor of the heroin distribution conspiracy, but not the crystal methamphetamine conspiracy. The Court also rejected Caballero's argument that Alleyne mandates a jury to determine safety-valve eligibility, affirming that judicial fact-finding by a preponderance of the evidence for safety-valve criteria is constitutionally permissible as it potentially lessens, rather than increases, the mandatory minimum sentence. Therefore, the defendant's motion for a jury determination was denied.