Clarifying the Scope of Plea Agreement Promises and Substantive Reasonableness of Sentences: United States v. Niselio Barros Garcia, Jr.

Introduction

United States v. Niselio Barros Garcia, Jr. is a 2025 decision of the Eleventh Circuit Court of Appeals addressing two core issues:

Whether the government breached the plea agreement by refusing to recommend a self-surrender date at sentencing.
Whether the within-Guidelines 48-month prison term imposed on Garcia is substantively unreasonable under 18 U.S.C. § 3553(a).

The defendant, charged with conspiracy to commit money laundering and related counts, pleaded guilty under an agreement that dismissed other charges in exchange for his plea to one count. At sentencing, his request to remain free over the summer and self-surrender later met with no government objection at the plea hearing, but was denied at sentencing once the government characterized Garcia as uncooperative and a flight risk. Garcia appealed both the alleged breach of the plea deal and the substantive reasonableness of his sentence.

Summary of the Judgment

In an unpublished per curiam opinion, the Eleventh Circuit affirmed. It held that:

The plea agreement’s unambiguous terms contained no promise regarding self-surrender. The government had expressly reserved “the right to make any recommendation as to the quality and quantity of punishment.” Thus no material promise was breached, and plain-error review did not warrant relief.
The 48-month term, within the 46–57-month Guidelines range and well below the 20-year statutory maximum, was substantively reasonable. The district court adequately considered the Section 3553(a) factors, weighed Garcia’s family hardships against the seriousness of the offense and his partial post-plea cooperation, and explained its sentencing choice.

Accordingly, the conviction and sentence were affirmed.

Analysis

Precedents Cited

United States v. Malone, 51 F.4th 1311 (11th Cir. 2022) – Standard for breach-of-plea-agreement review and interpreting government promises.
Johnson v. United States, 520 U.S. 461 (1997) – Elements of plain-error review.
United States v. Sosa, 782 F.3d 630 (11th Cir. 2015) – Plainness requirement for appellate review of plea breaches.
United States v. Rodriguez, 398 F.3d 1291 (11th Cir. 2005) – Miscarriage of justice in plain-error context.
Gall v. United States, 552 U.S. 38 (2007) – Framework for substantive reasonableness under § 3553(a).
United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015) – Abuse-of-discretion guideposts for sentencing.
Irey (en banc), 612 F.3d 1160 (11th Cir. 2010) – “Definite and firm conviction” standard for vacating a sentence.

Legal Reasoning

1. Scope of the Plea Agreement and Breach Analysis:
The court applied an objective inquiry to determine whether Garcia’s “reasonable understanding” of the government’s promises included a commitment to recommend self-surrender. The agreement was explicit that only certain guidelines calculations were binding recommendations and that, beyond those terms, the government could recommend “the quality and quantity of punishment.” A boilerplate “entire understanding” clause foreclosed any additional, unwritten promises. Because the plea agreement contained no unambiguous pledge regarding self-surrender, there was no breach. Even if an arguable error arose, it was not “plain” and did not affect substantial rights.

2. Substantive Reasonableness of the Sentence:
The court reviewed the sentence for abuse of discretion, considering the totality of the circumstances and the 18 U.S.C. § 3553(a) factors. It found that the district court:

Adopted the presentence investigation report without objection.
Considered the seriousness of Garcia’s laundering role in victimizing elderly and vulnerable targets.
Weighed Garcia’s family hardships and post-plea remorse against evidence of partial non-cooperation.
Chose a mid-range sentence of 48 months—within the Guidelines range and below the statutory maximum—consistent with deterrence, respect for the law, and just punishment.

As such, the sentence was neither “greater than necessary” nor shocking to the judicial conscience.

Impact

United States v. Garcia reinforces two important principles:

Plea-Agreement Drafting: Parties should expressly document any commitment about self-surrender dates or other post-sentencing recommendations. Courts will enforce the literal terms without reading in extrinsic side-agreements.
Appellate Deference in Sentencing: District courts have broad discretion to weigh family difficulties, offender characteristics, and offense seriousness. Within-Guidelines sentences, particularly well-below statutory maxima, enjoy a presumption of reasonableness absent a clear failure to address key § 3553(a) factors.

Complex Concepts Simplified

Plain-Error Review: A high hurdle on appeal when a defendant fails to object in district court. The error must be “clear or obvious,” affect the outcome, and undermine judicial integrity.
Advisory Guidelines Range: The Sentencing Guidelines provide a recommended sentencing bracket. District courts may vary from it but must consider it.
Section 3553(a) Factors: Statutory criteria requiring consideration of offense nature, history and characteristics of the defendant, purposes of sentencing (deterrence, public protection, just punishment), sentencing disparities, and restitution.
Substantive Reasonableness: Appellate review focuses on whether the trial court’s sentence was within a reasonable range given the facts and factors, not on whether the appellate court might have imposed a different term.

Conclusion

United States v. Garcia clarifies that plea-agreement promises must be spelled out in unambiguous language, and that appellate courts will not infer additional commitments from colloquy or negotiation. It also underscores the broad latitude afforded to sentencing courts in balancing offense gravity, defendant circumstances, and deterrence goals under § 3553(a). For practitioners, the decision reinforces the importance of precise plea-deal drafting and the prudent presentation of mitigating evidence at sentencing, but it affirms that an within-Guidelines sentence—especially well below statutory caps—will rarely be disturbed on appeal.