Rosales-Mireles v. United States

This case asked whether an appeals court uses the wrong standard for plain error (an obvious mistake) when a federal sentence is based on a miscalculated Sentencing Guidelines range. The Supreme Court said that when this kind of mistake affects a defendant's substantial rights, an appeals court generally should vacate the sentence and rejected the Fifth Circuit's stricter approach.

The Court ruled for Rosales-Mireles and rejected the Fifth Circuit's "shock the conscience" style restriction, but the vote and opinion lineup are not provided here.

The decision makes it easier for defendants to get a new sentencing hearing when a judge used the wrong Guidelines range. For example, a person sentenced after a criminal-history scoring mistake may now have a stronger chance to correct that sentence on appeal.

The Supreme Court has finished this case. The practical next step is for lower courts to apply this rule when reviewing similar sentencing errors.

The dispute was over how hard it should be to fix an obvious sentencing mistake on appeal. Rosales-Mireles argued the Fifth Circuit used a standard that was too strict.

Federal criminal defendants are most directly affected, especially those sentenced under a wrongly calculated Guidelines range. Appeals courts also must review these mistakes under a more forgiving rule.

The Supreme Court's work on this case is done. Lower courts must now follow this decision when similar sentencing-calculation errors are raised on appeal.