Case Explained: UNITED STATES OF AMERICA v. CARLOS ALBERTO MORILLA

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-11 Docket: 1:23-cr-20153-KMM-4 The eleventh-circuit affirmed the district court’s denial of a minor-role adjustment but vacated the sentence due to an erroneous application of the “sophisticated laundering” sentencing enhancement and a procedurally defective alternative-sentence statement. The court held that the district court committed reversible error by applying the two-level enhancement under U.S.S.G. § 2S1.1(b)(3) based on a generalized view of the conspiracy’s conduct rather than making individualized findings regarding Morilla’s specific relevant conduct. The court reasoned that because Morilla joined the conspiracy after it began and engaged in only one-layer, single-step transfers using his own accounts without shell corporations or offshore facilities, the record did not support the enhancement. Furthermore, the court ruled that the district court’s statement under *United States v. Keene*—intending to impose the same sentence regardless of Guidelines errors—was ineffective because it was made before the court heard arguments on 18 U.S.C. § 3553(a) factors and before Morilla had an opportunity to allocute. The court determined that a premature *Keene* statement fails to demonstrate that the sentence would remain reasonable after a full, individualized consideration of statutory sentencing factors. Consequently, the court remanded the case for resentencing consistent with this opinion, requiring the district court to recalculate the Guidelines range without the sophisticated-laundering enhancement and conduct a proper § 3553(a) analysis before imposing a sentence. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.