Case Explained: UNITED STATES OF AMERICA v. MIGUEL EDUARDO ROSARIO

Court: United States Court of Appeals for the Third Circuit Filed: 2026-07-01 The Third Circuit affirmed Miguel Rosario’s convictions for drug trafficking resulting in death and serious bodily injury, conspiracy to possess with intent to distribute, and possession of firearms in furtherance of drug trafficking, but vacated his statutorily mandated life sentence and remanded the case for resentencing. Regarding the Fourth Amendment challenge, the court held that the “good faith exception” to the exclusionary rule shielded Facebook communications seized pursuant to a search warrant from suppression, finding that Trooper Bailey’s reliance on the warrant was objectively reasonable despite Rosario’s arguments regarding the affidavit’s specificity and alleged misstatements. On the sufficiency of the evidence, the court ruled that accepting firearms in exchange for drugs constitutes “possession” under 18 U.S.C. § 924(c)(1)(A) and that the evidence supported a finding that such possession furthered drug trafficking. The court also upheld evidentiary rulings admitting hearsay statements by the victim as declarations against penal interest under Federal Rule of Evidence 804(b)(3). Regarding sentencing, the court rejected Rosario’s constitutional challenges to 21 U.S.C. § 841(b)(1)(C), holding that the mandatory life sentence for recidivist drug offenders does not violate the Eighth Amendment or equal protection guarantees. However, the court agreed with Rosario that the District Court erred by applying a “looser” conduct-based methodology to determine if his prior state convictions qualified as “felony drug offenses.” The court clarified that § 841(b)(1)(C) requires the traditional categorical approach established in *Taylor v. United States*, which mandates comparing the elements of the prior state statutes against the federal definition rather than examining the underlying conduct. Consequently, the sentence was vacated to allow the District Court to re-evaluate Rosario’s prior convictions using the correct legal standard. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.