United States v. Tello Cedeno

Background Defendant Carlos Rafael Tello Cedeno was arrested in 2016 while serving as the master of a go-fast boat involved in a large-scale cocaine smuggling operation. Coast Guard personnel intercepted the vessel in international waters, disabled it with gunfire, and recovered nearly seven hundred eighty-eight kilograms of cocaine that the crew had jettisoned. Cedeno pleaded guilty to conspiracy to distribute cocaine and was sentenced to one hundred sixty-eight months of imprisonment. In 2025, Cedeno filed a motion to reduce his sentence under Section thirty-five eighty-two subsection C two, arguing that Amendment Eight hundred twenty-one to the sentencing guidelines made him eligible for a lower advisory range. The district court denied the motion, citing the seriousness of the offense, the dangerous obstruction of the investigation, and Cedeno’s continued involvement in the drug trade. The court’s reasoning The Eleventh Circuit reviewed the district court’s denial for an abuse of discretion. The court explained that Section thirty-five eighty-two subsection C two requires a two-step inquiry: first, calculating the amended guideline range, and second, considering the Section thirty-five fifty-three A factors to determine if a reduction is warranted. The court noted that the district court correctly calculated the new advisory range but found that the second step allowed the court to consider the defendant’s obstructive conduct. The opinion states that conduct related to a possible guidelines enhancement may be considered when balancing the Section thirty-five fifty-three A factors. The court concluded that the district court did not make a clearly erroneous factual finding regarding the dangerous obstruction and did not abuse its discretion in weighing the factors against the reduction. What it means going forward The decision reinforces that district courts retain broad discretion to deny sentence reductions under Section thirty-five eighty-two subsection C two when the nature of the offense and obstructive conduct weigh heavily against a lower term, even if the defendant is technically eligible for a reduced guideline range.