Clarifying the Four-Part Mitigating Role Analysis Under U.S.S.G. § 3B1.2

Comprehensive Commentary on United States v. Ceballos, No. 23-1610 (1st Cir. 2025)

Introduction

The First Circuit’s decision in United States v. Ceballos sharpens the analytical lens through which sentencing courts must view a request for a mitigating-role adjustment under § 3B1.2 of the United States Sentencing Guidelines (U.S.S.G.). Disavowing conclusory denials and narrow conceptions of “participants,” the court vacated José Miguel Guzmán-Ceballos’s 90-month sentence for maritime drug trafficking and remanded for de novo resentencing.

At its core, the case addresses whether the district court performed the “four-part analysis” mandated by the circuit’s burgeoning line of authority—particularly United States v. Guía-Sendeme (2025)—when evaluating a defendant’s relative culpability. The decision firmly reiterates that a court commits procedural error if it:

1. fails to identify all discernible participants in the criminal enterprise;
2. neglects to place each participant on a spectrum of culpability;
3. omits designation of the “average participant;” and
4. does not compare the defendant to that average using the five § 3B1.2 factors.

Because the district court limited its view to “the three people on the boat” and furnished virtually no reasoning, the First Circuit held the sentence procedurally unreasonable.

Summary of the Judgment

• Holding: The district court abused its discretion by denying a mitigating-role reduction without conducting the requisite four-step inquiry. Sentence vacated and remanded.
• Key Point of Law: Sentencing courts must expressly—or at least demonstrably—apply the four-part analysis and the five § 3B1.2 factors; limiting the “universe of participants” to only those physically present during interdiction is error.
• Standard of Review: Preserved procedural sentencing errors are reviewed for abuse of discretion, entailing de novo review of legal questions and clear-error review of fact-finding.
• Outcome for Defendant: Opportunity for a lower advisory guideline range (and possibly benefit from post-2023 Amendment 821) on remand.

Analysis

Precedents Cited and Their Influence

1. Gall v. United States, 552 U.S. 38 (2007) – Established that correct guideline calculation is the first step in sentencing and requires adequate explanation for variances.
2. United States v. Guía-Sendeme, 134 F.4th 611 (1st Cir. 2025) – Articulated the four-part analysis central to Ceballos; emphasised considering all likely participants, not merely couriers present on the vessel.
3. United States v. Walker, 89 F.4th 173 (1st Cir. 2023) – Clarified necessity to address § 3B1.2 factors even briefly and to compare the defendant with the “average participant.”
4. United States v. Quirós-Morales, 83 F.4th 79 (1st Cir. 2023) & Koon v. United States, 518 U.S. 81 (1996) – Reaffirmed that legal errors in guideline application constitute per se abuse of discretion.
5. Procedural-preservation cases—Rivera-Berríos, Soto-Soto, and others—determined that general yet direct objections suffice to preserve appellate review.
6. Comparative precedents from other circuits—e.g., United States v. Wynn, 37 F.4th 63 (2d Cir. 2022)—echo the need for explicit factor analysis.

By aligning itself with Guía-Sendeme and Walker, the panel cements a coherent, step-by-step framework that district courts in the First Circuit must follow, thereby promoting uniformity and transparency in guideline application.

Legal Reasoning

The court proceeded in two analytical stages:

1. Preservation and Standard of Review. Concluding that Guzmán-Ceballos’s objections—both at the PSR stage and after pronouncement of sentence—were “sufficiently specific,” the court applied abuse-of-discretion review.
2. Merits.
   • Absence of four-part analysis constituted legal error.
   • District court’s reference to § 3553(a) factors and “participation” did not substitute for required comparison to the average participant.
   • Limiting the universe to “three people on the boat” ignored evidence of “at least six others at the beach” and contradicted § 1B1.3’s relevant-conduct mandate.
   • Failure to articulate consideration of the five § 3B1.2 factors precluded meaningful appellate review under Gall.

Impact on Future Cases and Sentencing Practice

• Heightened Judicial Articulation: District judges within the First Circuit must now articulate—on the record—each step of the four-part inquiry or risk reversal.
• Broader “Participant Universe” in Drug-Smuggling Cases: Prosecutors and defendants alike must marshal evidence about shore-based organizers, financers, lookouts, and logistics personnel. Defense counsel can leverage this broader array to argue for role reductions.
• Guideline Consistency:** The decision discourages perfunctory reliance on the PSR, compelling probation officers to draft more comprehensive participant analyses.
• Amendment 821 Synergy: The remand, coupled with the court’s notable footnote, paves the way for litigants to seek benefit from retroactive criminal-history amendments, potentially lowering ranges further.
• Inter-Circuit Dialogue: By citing Second Circuit authority (Wynn), the panel signals alignment with nationwide trends, bolstering persuasive force in circuits yet to crystallize a four-part test.