Case Explained: United States of America Plaintiff— v. Ramon Aguayo-Galvez Defendant—

Court: United States Court of Appeals for the Fifth Circuit Filed: 2026-06-25 The Fifth Circuit vacated Ramon Aguayo-Galvez’s sentence and remanded the case for resentencing because the district court clearly erred in applying a two-level sentencing enhancement under U.S.S.G. § 2L1.1(b)(8)(A) for “involuntarily detained” aliens. The court held that the term “involuntarily detained” requires proof that an alien was held or confined against their will through coercion, threat, or a demand for payment. While the district court relied on the Presentence Report’s finding that aliens were extorted to continue staying at a stash house, the Fifth Circuit determined that paying to remain in a location does not constitute involuntary detention under the Guidelines when there is no evidence that the defendants prevented the aliens from leaving or threatened them with immediate harm or deportation if they departed. The court distinguished this case from precedent where enhancements were upheld because the facts here showed only a demand for payment for continued stay, not a restriction on freedom of movement. Furthermore, the court rejected the Government’s argument that any error was harmless. Under Fifth Circuit precedent, the Government bears a heavy burden to demonstrate that an erroneous Guidelines calculation did not influence the district court’s selection of the sentence. The court found this burden unmet because the district court imposed a sentence at the very bottom of the incorrect Guidelines range and explicitly stated it adopted the Probation Office’s calculations. Although the judge included a general statement that he would impose the same sentence regardless of the Guidelines error based on 18 U.S.C. § 3553(a) factors, the record lacked specific evidence or independent reasoning showing that the court had a particular sentence in mind and would have reached it without relying on the erroneous range. Consequently, the sentence is vacated, and the case is remanded to the district court for resentencing consistent with the correct Guidelines calculation. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.