Reaffirming Firearm Foreseeability in Maritime Drug Conspiracies: Commentary on United States v. Garcia‑Castillo (11th Cir. 2025)

I. Introduction

This commentary analyzes the Eleventh Circuit’s unpublished, per curiam decision in United States v. Luis Manuel Garcia‑Castillo, No. 24‑12065 (11th Cir. Nov. 19, 2025), arising from a high‑volume maritime cocaine trafficking case under the Maritime Drug Law Enforcement Act (MDLEA).

Two poor Dominican fishermen—Luis Manuel Garcia‑Castillo and his co‑defendant Miguel Angel Perez‑Abad—were recruited to transport approximately 410 kilograms of cocaine by boat between Colombia and the Dominican Republic. The U.S. Coast Guard intercepted their small vessel approximately 130 nautical miles off the Dominican coast, on the high seas, and recovered not only the cocaine but also a loaded firearm hidden in a bucket under other items, including a GPS device.

Garcia‑Castillo pleaded guilty to:

Conspiracy to possess with intent to distribute five kilograms or more of cocaine while on board a vessel subject to U.S. jurisdiction; and
Possession with intent to distribute five kilograms or more of cocaine while on board such a vessel.

The district court imposed a 108‑month sentence, within the advisory Guidelines range. On appeal, Garcia‑Castillo raised two principal challenges:

That the district court erred in applying the two‑level firearm enhancement under U.S.S.G. § 2D1.1(b)(1); and
That his 108‑month sentence was substantively unreasonable, including on the ground that it created an unwarranted sentencing disparity vis‑à‑vis his co‑defendant.

The Eleventh Circuit affirmed. While the opinion is “Not for publication” and thus not binding precedent within the circuit, it is a clear and instructive application of existing doctrine on:

The firearm enhancement in drug cases, especially as applied to co‑conspirator possession; and
The deferential review of within‑Guidelines sentences under the “substantive reasonableness” standard.

At its core, the decision powerfully reaffirms that in large‑scale drug conspiracies—here, maritime smuggling of hundreds of kilograms of cocaine—it is ordinarily reasonably foreseeable that co‑conspirators will use or possess firearms, even if a particular defendant claims ignorance. The case also illustrates the practical difficulty that low‑level couriers face in avoiding firearm enhancements and in achieving meaningful sentence reductions on appeal.

II. Summary of the Opinion

A. Holding on the Firearm Enhancement

The court upheld the two‑level enhancement under U.S.S.G. § 2D1.1(b)(1), which applies “[i]f a dangerous weapon (including a firearm) was possessed” in connection with a drug offense.

Key points:

The government satisfied its initial burden by showing that a firearm was present on the boat that simultaneously carried approximately 410 kilograms of cocaine.
Once the government showed presence and proximity, the burden shifted to Garcia‑Castillo to prove that it was “clearly improbable” that the firearm was connected to the offense; he produced no evidence to meet this heavy burden.
Even if Garcia‑Castillo did not personally know about the firearm, the enhancement was still proper under co‑conspirator liability principles because it was reasonably foreseeable that a co‑conspirator would place a firearm aboard a vessel transporting such a large quantity of cocaine across international waters.

B. Holding on Substantive Reasonableness

The Eleventh Circuit also rejected the substantive reasonableness challenge and affirmed the 108‑month sentence:

The district court thoroughly considered the 18 U.S.C. § 3553(a) factors, emphasizing the seriousness of transporting hundreds of kilograms of cocaine and the increased danger from the presence of the firearm.
The sentence fell within the Guidelines range (108–135 months) and below the statutory maximum of life imprisonment—considerations that support reasonableness under circuit precedent.
The court was entitled to give greater weight to the seriousness of the offense than to mitigating personal circumstances such as poverty, physical disability, and family hardship.
Sentencing both Garcia‑Castillo and his co‑defendant to 108 months did not create an unwarranted disparity: they were “very similarly situated,” jointly recruited, and assigned the same role. The captain enhancement was removed as to Perez‑Abad, further aligning their culpability.

III. Case Background and Procedural History

A. Facts of the Offense

In October 2023, the U.S. Coast Guard intercepted a small, 25‑foot go‑fast boat approximately 130 nautical miles from the Dominican Republic. The vessel displayed no flag or other indicia of nationality. On board were:

Luis Manuel Garcia‑Castillo (defendant‑appellant), and
Miguel Angel Perez‑Abad (co‑defendant, non‑appellant).

Perez‑Abad identified himself as the vessel’s master and claimed Dominican nationality for the boat. The United States contacted the Dominican government, which could neither confirm nor deny the boat’s nationality. Under international law and U.S. statutes governing the MDLEA, this failure to confirm or deny allowed the U.S. to treat the vessel as “without nationality”—effectively stateless—and thus subject to the jurisdiction of the United States.

The Coast Guard recovered:

Approximately 410 kilograms of cocaine in bales; and
A loaded firearm found inside a five‑gallon bucket, concealed beneath other items, including a GPS device.

The PSR reported that both men were subsistence‑level fishermen in the Dominican Republic. An unidentified man recruited them for a drug run. The plan was:

Use the 25‑foot boat (with a single 150‑horsepower engine) to travel from the Dominican Republic to Colombia;
Wait in Colombia until instructed to return;
Depart Colombia with the boat loaded with cocaine, guided by GPS devices, and bring the load back to the Dominican Republic; and
Receive relatively modest payment (“a few thousand dollars”) for the dangerous undertaking.

B. Charges and Guilty Plea

A federal grand jury in the Southern District of Florida indicted both defendants on:

Count One: Conspiracy to possess with intent to distribute five kilograms or more of cocaine while on board a vessel subject to the jurisdiction of the United States;
Count Two: Possession with intent to distribute five kilograms or more of cocaine while on board such a vessel.

Both defendants pleaded guilty to both counts. Perez‑Abad did not appeal; his case remains relevant only insofar as it bears on sentencing disparity arguments.

C. Guidelines Calculations and Objections

1. Garcia‑Castillo’s Presentence Report

For Garcia‑Castillo, the PSR calculated:

Base offense level 36, driven by the drug quantity (410 kg of cocaine) under U.S.S.G. § 2D1.1(a)(5), (c)(2);
+2 levels for possession of a firearm, U.S.S.G. § 2D1.1(b)(1);
−2 levels for “safety valve” relief under § 5C1.2 (also linked to 18 U.S.C. § 3553(f));
−3 levels for acceptance of responsibility under § 3E1.1; and
−2 levels for being a “zero‑point offender” (no criminal history points) under § 4C1.1.

Total offense level: 31.
Criminal history category: I (no criminal history points).
Advisory Guidelines range: 108–135 months.
Statutory maximum: life imprisonment.

Garcia‑Castillo objected only to the firearm enhancement; he did not object to the PSR’s factual narrative of how the trip was organized.

2. Perez‑Abad’s Presentence Report

Perez‑Abad’s PSR:

Included a two‑level “captain” enhancement under § 2D1.1(b)(3)(C) (for acting as captain/pilot/master of a drug‑carrying vessel); and
Also included the two‑level firearm enhancement under § 2D1.1(b)(1).

He objected to both. At sentencing, the government agreed that the captain enhancement was not warranted; the district court removed it.

D. Joint Sentencing Hearing and Sentences Imposed

The district court held a joint sentencing hearing. Both defendants contested the firearm enhancement, arguing that:

They did not know the gun was aboard;
It was hidden and only discovered by the Coast Guard; and
It may have been inadvertently left on the boat by the unidentified loaders in Colombia, unrelated to the drug run.

The government responded that:

The enhancement applies whenever a firearm is present unless it is “clearly improbable” that the weapon was connected to the drug offense;
The firearm was found on a small vessel carrying a massive quantity of cocaine, hidden with navigation equipment; and
At a minimum, a co‑conspirator placed the firearm on the boat in furtherance of the conspiracy, and it was reasonably foreseeable that a firearm would be present given the scale of the smuggling operation.

The court agreed and applied the firearm enhancement to both men, yielding the same Guidelines range—108 to 135 months—for each.

On sentencing:

The government requested 120 months for each defendant, emphasizing the seriousness of smuggling hundreds of kilograms of cocaine and the presence of a weapon.
Both defense lawyers requested a downward variance to 87 months, stressing similar mitigating themes:
- Poverty and economic desperation;
- Limited roles as low‑level couriers/crew;
- Minimal expected financial gain;
- Tragic personal histories (e.g., Garcia‑Castillo’s childhood loss of an eye and the death of his first wife); and
- A lack of knowledge of the firearm’s presence.

The district court:

Considered the § 3553(a) factors, focusing on the seriousness of the offense and the increased danger due to the firearm;
Declined to vary downward; and
Imposed 108 months’ imprisonment on each defendant—at the very bottom of the Guidelines range.

Garcia‑Castillo renewed his objection to the firearm enhancement but raised no other objection to the sentence. He then appealed.

IV. Detailed Analysis of the Opinion

A. Standards of Review

1. Firearm Enhancement – Mixed Standard

The Eleventh Circuit reiterated its established two‑tiered standard (citing United States v. Pham, 463 F.3d 1239 (11th Cir. 2006)):

Factual findings underlying the enhancement (e.g., presence of the firearm, the context of the offense, foreseeability) are reviewed for clear error; and
The legal application of the Guidelines to those facts is reviewed de novo.

“Clear error” is a deferential standard: if the district court chooses between two permissible views of the evidence, the appellate court will not overturn its finding (United States v. Almedina, 686 F.3d 1312 (11th Cir. 2012)).

2. Substantive Reasonableness – Abuse of Discretion

Sentences are reviewed for substantive reasonableness under the abuse‑of‑discretion standard (citing Gall v. United States, 552 U.S. 38 (2007)).

The Eleventh Circuit uses language from its en banc decision in United States v. Irey, 612 F.3d 1160 (11th Cir. 2010), explaining that reversal is warranted only when the panel has a:

“definite and firm conviction that the district court committed a clear error of judgment in weighing the § 3553(a) factors.”

The weight assigned to any particular § 3553(a) factor lies within the district court’s “sound discretion” (United States v. Croteau, 819 F.3d 1293 (11th Cir. 2016)), and the defendant bears the burden of showing that a sentence is substantively unreasonable (United States v. Boone, 97 F.4th 1331 (11th Cir. 2024)).

B. The Firearm Enhancement Under U.S.S.G. § 2D1.1(b)(1)

1. Legal Framework

Section 2D1.1(b)(1) of the U.S. Sentencing Guidelines provides for a two‑level increase “[i]f a dangerous weapon (including a firearm) was possessed” in connection with a drug trafficking offense.

The Sentencing Commission’s commentary (Application Note 11) states:

“The enhancement for weapon possession reflects the increased danger of violence when drug traffickers possess weapons. The enhancement should be applied if the weapon was present, unless it is clearly improbable that the weapon was connected with the offense.”

This creates:

An initial burden on the government to show by a preponderance of the evidence that a firearm was present at the site of the charged conduct or possessed during conduct associated with the offense (United States v. George, 872 F.3d 1197 (11th Cir. 2017)); often, proximity between guns and drugs suffices (United States v. Carrillo‑Ayala, 713 F.3d 82 (11th Cir. 2013)).
A shifted burden to the defendant to show that the connection between the weapon and the offense is “clearly improbable”—a “heavy burden” (Carrillo‑Ayala).

Crucially, in a conspiracy, the enhancement may apply even when the firearm is possessed by a co‑conspirator, under Guidelines § 1B1.3(a)(1)(B) (relevant conduct). The government must show:

the possessor was a co‑conspirator;
the possession was in furtherance of the conspiracy;
the defendant was a member of the conspiracy when the possession occurred; and
the co‑conspirator’s possession was reasonably foreseeable to the defendant.

The Eleventh Circuit in Pham expressly held that it is reasonably foreseeable that co‑conspirators will possess firearms in conspiracies involving “lucrative and illegal drugs.”

2. Application to the Facts

The panel concluded that the district court properly applied the enhancement to Garcia‑Castillo.

a. Government’s Initial Burden – Presence and Proximity

The firearm was found:

On the small boat carrying approximately 410 kilograms of cocaine;
In a five‑gallon bucket; and
Under other items, including a GPS device used for navigation.

This established both:

Presence of the weapon at the site of the charged conduct; and
Proximity to a very large quantity of drugs in a confined setting (a 25‑foot vessel).

Under George and Carrillo‑Ayala, this easily satisfied the government’s preponderance‑of‑the‑evidence burden. The burden then shifted.

b. Defendant’s Heavy Burden – “Clearly Improbable” Connection

Garcia‑Castillo’s only counter was that:

He did not know the firearm was aboard; and
It might have been accidentally left there by unidentified loaders.

But:

He introduced no affirmative evidence that the firearm was unrelated to the smuggling operation;
He did not identify who allegedly left the gun or why they would have done so for reasons unrelated to the shipment; and
The location of the firearm—on a small boat crossing international waters, transporting a massive quantity of high‑value narcotics—made it entirely plausible (indeed, quite likely) that the weapon was for protection of the cargo and crew.

Drawing on United States v. Fields, 408 F.3d 1356 (11th Cir. 2005), where drugs and guns together in drug‑selling locations made connection not “clearly improbable,” the panel held that it was not clearly improbable that the gun here was connected to the drug offense. To the contrary, the circumstances made a connection likely.

c. Co‑Conspirator Possession and Foreseeability

The panel also reasoned that—even assuming Garcia‑Castillo personally did not possess the firearm—the enhancement was justified by co‑conspirator liability.

The court invoked the rule from Pham and Freyre‑Lazaro:

It is reasonably foreseeable that a co‑conspirator will carry or possess a firearm in a conspiracy involving the transportation of large quantities of cocaine, as weapons are commonly used to protect valuable illegal cargo and the individuals handling it.

Applying that doctrine:

This was a conspiracy to move hundreds of kilograms of cocaine—an extremely valuable and high‑risk load—across international waters.
A co‑conspirator (likely those who loaded the cocaine in Colombia) could easily choose to place a firearm aboard for protection.
Given the nature and scale of the criminal enterprise, it was reasonably foreseeable to a participant like Garcia‑Castillo that a firearm might be present.

Thus, even without proof that Garcia‑Castillo knew of the gun, he was fairly held accountable for the co‑conspirator’s firearm possession under U.S.S.G. § 1B1.3(a)(1)(B).

3. Significance of the Holding on the Firearm Enhancement

The decision strongly reinforces—now explicitly in the context of a maritime smuggling case—that:

The threshold for the government to invoke § 2D1.1(b)(1) is relatively low where a firearm is physically present with drugs; and
The defendant faces a very high bar to show that the connection is “clearly improbable,” especially in high‑volume conspiracies.

It also underscores that:

Claims of “I didn’t know about the gun” will rarely suffice; knowledge is not an element of the enhancement if co‑conspirator foreseeability can be shown.
In large‑scale maritime cases, courts are prepared to treat firearms as a predictable, foreseeable adjunct to the enterprise, even for low‑level couriers.

For practitioners, the opinion signals that if a weapon is found anywhere on a drug‑smuggling vessel, defeating the enhancement will likely require specific evidence explaining an innocent or unrelated purpose—not merely speculation.

C. Substantive Reasonableness and the § 3553(a) Factors

1. The District Court’s Reasoning

The district court grounded its 108‑month sentence in the § 3553(a) factors. It emphasized:

The nature and circumstances of the offense: a transnational conspiracy to smuggle a very large quantity (410 kg) of cocaine by boat, which is inherently dangerous.
The seriousness of the offense and the need for a sentence that would:
- Reflect that seriousness;
- Promote respect for the law; and
- Provide just punishment and deterrence.
The fact that a firearm was present on the vessel, making this offense “more serious” than otherwise‑similar maritime drug smuggling cases.

While acknowledging Garcia‑Castillo’s personal hardships—poverty, disability, tragic family history—the court ultimately concluded they did not justify a downward variance in light of the gravity and international character of the crime.

2. The Eleventh Circuit’s Review

The appellate panel upheld the sentence as substantively reasonable, focusing on:

Consideration of § 3553(a): The record showed that the district court meaningfully engaged with and weighed the statutory factors.
Guidelines range: The sentence was at the bottom of the properly calculated Guidelines range (108–135 months).
Statutory maximum: The statutory maximum was life imprisonment; a 108‑month (9‑year) term is “well below” that, a factor that “indicates reasonableness” under United States v. Woodson, 30 F.4th 1295 (11th Cir. 2022).
Weight of mitigating factors: Although the defendant’s personal circumstances could have justified a lower sentence, the court reiterated that it is for the district judge—not the appellate court—to decide how much weight to assign such factors (citing Croteau).

Thus, even if a reviewing court might have chosen a different sentence in the first instance, that is not the test. The question is whether the sentence imposed lies “within the range of reasonable sentences dictated by the facts of the case.” The panel found that it did.

D. Alleged Unwarranted Sentencing Disparity

1. Legal Background – § 3553(a)(6)

Section 3553(a)(6) directs district courts to consider “the need to avoid unwarranted sentence disparities among defendants with similar records who have been found guilty of similar conduct.”

This does not guarantee identical sentences for co‑defendants, nor does it mandate harsher treatment of one defendant simply because he appears marginally more culpable. It requires a reasoned approach to relative culpability and sentencing outcomes.

2. Garcia‑Castillo’s Argument

On appeal, Garcia‑Castillo argued that his and Perez‑Abad’s identical sentences (108 months each) created an unwarranted disparity because:

Perez‑Abad initially identified himself as the “master of the vessel” to the Coast Guard; and
Thus, according to Garcia‑Castillo, Perez‑Abad should have received a longer sentence as more culpable.

3. The Court’s Response

The panel rejected this argument for several reasons:

The district court did not apply the captain enhancement (§ 2D1.1(b)(3)(C)) to Perez‑Abad. The government conceded, and the court accepted, that a two‑level enhancement for acting as captain was unwarranted. Thus, formally, both men were treated as having equivalent roles for Guidelines purposes.
At sentencing, Garcia‑Castillo himself argued that he and Perez‑Abad were “very similarly situated.” The panel cited this admission to undermine his later claim that he was less culpable.
Garcia‑Castillo did not object to the PSR’s factual narrative that they were recruited together and assigned the same shared responsibilities on the trip. Under United States v. Howard, 742 F.3d 1334 (11th Cir. 2014), unobjected‑to facts in a PSR are taken as true and may be used in applying § 3553(a).

Given those facts, the district court’s decision to impose identical bottom‑of‑range sentences did not create an unwarranted disparity. To the contrary, treating the two co‑participants similarly was consistent with § 3553(a)(6).

V. Precedents and Authorities Cited

A. Firearm Enhancement and Co‑Conspirator Liability

United States v. Pham, 463 F.3d 1239 (11th Cir. 2006) – Established that § 2D1.1(b)(1) applies when a firearm is possessed by a co‑conspirator if:
- The co‑conspirator possessed the firearm in furtherance of the conspiracy;
- The defendant was a member of the conspiracy at the time; and
- Possession was reasonably foreseeable to the defendant.
Pham also recognized that in conspiracies involving “lucrative and illegal drugs,” it is ordinarily foreseeable that co‑conspirators will possess firearms.
United States v. Carrillo‑Ayala, 713 F.3d 82 (11th Cir. 2013) – Emphasized that:
- “Proximity between guns and drugs” can satisfy the government’s initial burden for the enhancement;
- The defendant bears a “heavy burden” to show that the connection is “clearly improbable.”
United States v. George, 872 F.3d 1197 (11th Cir. 2017) – Clarified the burden‑shifting structure: the government must first show presence of a weapon at the site of the offense; the defendant then must prove the “clearly improbable” exception.
United States v. Fields, 408 F.3d 1356 (11th Cir. 2005) – Held that in locations where drugs are sold, it is not “clearly improbable” that firearms present are there to protect the drug inventory and dealers, supporting the enhancement.
United States v. Freyre‑Lazaro, 3 F.3d 1496 (11th Cir. 1993) – Upheld the firearm enhancement where it was reasonably foreseeable that a co‑conspirator would carry a firearm while transporting thirteen kilograms of cocaine.

B. Standards of Review and Reasonableness

Gall v. United States, 552 U.S. 38 (2007) – Established abuse‑of‑discretion review for sentencing decisions after United States v. Booker, emphasizing deference to district court judgments.
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (en banc) – Articulated the “definite and firm conviction” standard for appellate reversal on substantive reasonableness grounds.
United States v. Croteau, 819 F.3d 1293 (11th Cir. 2016) – Reaffirmed that the weight assigned to each § 3553(a) factor is within the district court’s discretion.
United States v. Boone, 97 F.4th 1331 (11th Cir. 2024) – Confirmed that the defendant bears the burden of showing a sentence is substantively unreasonable.
United States v. Woodson, 30 F.4th 1295 (11th Cir. 2022) – Stated that a sentence within the Guidelines range and substantially below the statutory maximum is ordinarily expected to be reasonable.
United States v. Howard, 742 F.3d 1334 (11th Cir. 2014) – Held that unobjected‑to facts in a PSR are taken as true and can be used in the § 3553(a) analysis.
United States v. Almedina, 686 F.3d 1312 (11th Cir. 2012) – Clarified that factual findings are not clearly erroneous when the factfinder is choosing between two permissible views of the evidence.

VI. Complex Concepts Simplified

A. “Not for Publication” and “Non‑Argument Calendar”

Not for Publication: The opinion is designated as unpublished, meaning under Eleventh Circuit rules it is not binding precedent, but it may be cited as persuasive authority.
Non‑Argument Calendar: The case was decided without oral argument, based solely on the briefs and the record, often used when the issues are straightforward or controlled by existing precedent.

B. The MDLEA and “Vessel Without Nationality”

Although not deeply analyzed in the opinion, the case arises under the Maritime Drug Law Enforcement Act. A key jurisdictional feature:

A vessel is treated as “without nationality” (stateless) if the nation to which nationality is claimed cannot confirm or denies the vessel’s nationality.
Stateless vessels on the high seas are generally subject to the enforcement jurisdiction of states like the United States.

Here, when the Dominican Republic neither confirmed nor denied the vessel’s nationality, U.S. authorities were entitled to treat the craft as stateless and enforce U.S. drug laws against those aboard.

C. Sentencing Guidelines Concepts

Base Offense Level: Starting point determined largely by drug type and quantity; here, 410 kg of cocaine triggered level 36.
Specific Offense Characteristics: Enhancements or reductions tied to particular aspects of the offense (e.g., firearms, leadership roles, safety valve).
“Safety Valve” (§ 5C1.2 / 18 U.S.C. § 3553(f)): Allows qualifying low‑level, non‑violent, cooperative defendants to avoid certain mandatory minimum sentences and yields a two‑level reduction; here, it allowed the court to sentence below the 10‑year statutory minimum for 5+ kg of cocaine.
Zero‑Point Offender (§ 4C1.1): A newer guideline providing a two‑level reduction for first‑time offenders with zero criminal history points, reflecting a policy judgment that such offenders are less culpable and less risky.
Guidelines Range vs. Statutory Maximum: The Guidelines provide an advisory range (here, 108–135 months); the statute sets the outer legal limits (here, up to life). Courts consider both in evaluating reasonableness.

D. “Clearly Improbable” Connection between Weapon and Offense

The phrase “clearly improbable” comes from the commentary to § 2D1.1. It means:

It is the defendant’s job to dispel the natural inference that a gun found in proximity to drugs is there to protect the drugs or facilitate trafficking.
It is not enough to show that another story is plausible; the defendant must show it is clearly improbable that the gun was connected to the crime.

Example (from the Guidelines): if the defendant’s unloaded hunting rifle is found in a closet at his home, hours away from the drug transaction, that might be “clearly improbable.” In contrast, a loaded gun hidden on a small boat carrying 410 kg of cocaine across the sea is the opposite.

E. “Substantive Reasonableness” vs. “Procedural Reasonableness”

Procedural reasonableness concerns how the sentence was imposed: Were the Guidelines correctly calculated? Were the § 3553(a) factors considered? Was there reliance on clearly erroneous facts? Those issues were not meaningfully contested here.
Substantive reasonableness concerns what sentence was imposed: Given all the facts and factors, is the sentence too harsh or too lenient? That was Garcia‑Castillo’s focus on appeal. The standard is very deferential.

VII. Impact and Broader Significance

A. Reinforcing Firearm Foreseeability in High‑Volume Maritime Trafficking

Although unpublished, Garcia‑Castillo is a strong reaffirmation of the following practical principle:

In large‑scale maritime drug conspiracies, it is ordinarily foreseeable that a co‑conspirator will place a firearm aboard the vessel.

This has several concrete implications:

Low‑level couriers in MDLEA cases—often impoverished fishermen or laborers—face substantial difficulty avoiding the firearm enhancement whenever a weapon is found on the vessel.
Defense arguments based solely on lack of personal knowledge will rarely succeed in the Eleventh Circuit without additional evidence.
Prosecutors will likely continue to invoke § 2D1.1(b)(1) routinely in maritime smuggling cases where any weapon is recovered.

B. High Bar for Disturbing Within‑Guidelines Sentences

The decision also exemplifies the Eleventh Circuit’s continuing adherence to a highly deferential approach to within‑Guidelines sentences:

A bottom‑of‑range sentence well below the statutory maximum is “ordinarily expected” to be reasonable.
Personal hardships—poverty, family tragedy, physical disability—while relevant, rarely compel a variance on appeal unless the district court ignores them entirely or misapplies the law.
Defendants face a steep uphill battle in arguing that the district court gave too little weight to sympathetic history and characteristics.

C. Co‑Defendant Parity and Disparities

On § 3553(a)(6), the case reminds practitioners:

When co‑defendants are factually and role‑wise very similar, identical sentences are presumptively consistent with the goal of avoiding unwarranted disparity.
Defense counsel should be cautious about describing co‑defendants as “very similarly situated” at sentencing if they later intend to claim a disparity on appeal.
Factual assertions in the PSR that go unchallenged become powerful tools for the court to justify treating co‑defendants similarly.

D. Safety Valve and Zero‑Point Offender: Only So Much Relief

The case also illustrates the limits of recent leniency‑oriented reforms:

Garcia‑Castillo received both safety valve relief and the zero‑point offender reduction, which together significantly lowered his advisory range.
Yet, even with those reductions, the gravity of the offense and the firearm enhancement produced a substantial 9‑year sentence.

In other words, while the Guidelines now provide more tools for mercy for first‑time, low‑level offenders, those tools operate within the constraints of drug quantity and aggravating factors like weapons.

VIII. Conclusion

United States v. Garcia‑Castillo does not blaze new doctrinal trails, but it crystallizes and applies several important principles in the context of maritime cocaine trafficking:

A firearm found on a vessel carrying hundreds of kilograms of cocaine almost inevitably supports a § 2D1.1(b)(1) enhancement. The defendant’s burden to show a “clearly improbable” connection is extremely difficult to meet, especially absent concrete alternative explanations.
Co‑conspirator possession, grounded in foreseeability, is sufficient: in large‑scale drug conspiracies, it is ordinarily foreseeable that firearms will be present to protect the load and the participants.
Within‑Guidelines sentences, especially at the low end and far below the statutory maximum, receive substantial deference on appeal. The mere fact that mitigating facts could support a lower sentence is not enough to establish substantive unreasonableness.
Treating similarly situated co‑defendants alike is consistent with § 3553(a)(6), and defendants who acknowledge equal culpability at sentencing will find it difficult to later argue unwarranted disparity.

In the broader legal landscape, Garcia‑Castillo serves as a cautionary illustration of how heavily the federal sentencing structure weighs large‑scale drug trafficking and associated risks of violence, and how challenging it is—especially in the Eleventh Circuit—to disturb the resulting sentences on appeal. For maritime drug prosecutions in particular, it underscores that firearms and foreseeability will remain central, and often decisive, components of sentencing analysis.