Relevant-Conduct Anchoring for Minor-Role and “Verge of Completion” Limits on § 2X1.1(b) Reductions in Money-Laundering Conspiracies

I. Introduction

In United States v. Alejandra Florez-Meza (11th Cir. July 2, 2026) (unpublished, per curiam), the Eleventh Circuit affirmed a 63-month sentence imposed after Alejandra Florez-Meza pleaded guilty to conspiracy to commit money laundering under 18 U.S.C. § 1956(h). The case arose from a controlled law-enforcement operation in which a confidential source arranged an exchange involving $740,000 intended to be transported out of the United States for drug-related purposes.

On appeal, Florez-Meza argued the district court procedurally erred in calculating the advisory Sentencing Guidelines range by (1) denying her a minor-role reduction under U.S.S.G. § 3B1.2(b), and (2) denying her a three-level reduction under U.S.S.G. § 2X1.1(b) (attempt/conspiracy reduction) on the theory she did not complete all acts necessary to launder the funds because she was arrested before transporting the money to Colombia.

The key issues were therefore how role adjustments should be assessed in a conspiracy when the defendant is held accountable only for a discrete transaction, and when § 2X1.1(b) permits (or forecloses) a reduction where law enforcement interrupts the scheme near completion.

II. Summary of the Opinion

The Eleventh Circuit held the district court committed no procedural error. It affirmed two guideline rulings:

  1. No minor-role reduction (§ 3B1.2(b)): The court agreed Florez-Meza did not prove she was “less culpable than most other participants” as to the relevant conduct for which she was held accountable—namely, the single $740,000 laundering transaction.
  2. No § 2X1.1(b) three-level reduction: Because Florez-Meza had taken the steps she believed necessary and was “on the cusp” of completion when law enforcement intervened, the guideline’s “verge of completion” principle barred the reduction.

III. Analysis

A. Precedents Cited

1. Standards of review and procedural error framework

  • Gall v. United States, 552 U.S. 38 (2007): Provided the overarching sentencing-review sequence—appellate courts first ensure no “significant procedural error,” including miscalculation of the guideline range. The panel used Gall to frame the appeal strictly as a procedural-guidelines dispute.
  • United States v. Dupree, 57 F.4th 1269 (11th Cir. 2023) (en banc): Cited for de novo review of “interpretation and application” of the Guidelines. While the appeal turned largely on fact-bound application, Dupree anchored the panel’s review posture.
  • United States v. Rothenberg, 610 F.3d 621 (11th Cir. 2010): Cited for clear-error review of factual findings at sentencing, reinforcing deference to the district court on role determinations.

2. Minor-role doctrine and the “relevant conduct” anchor

  • United States v. De Varon, 175 F.3d 930 (11th Cir. 1999) (en banc): The controlling Eleventh Circuit framework for § 3B1.2. The panel relied on De Varon for three central propositions:
    1. The defendant bears the burden of proving entitlement to a mitigating-role reduction.
    2. “First and foremost,” role is measured against the relevant conduct attributed to the defendant, not necessarily the broader conspiracy.
    3. When relevant conduct equals actual conduct, the defendant generally cannot obtain a minor-role reduction by pointing to a broader scheme for which she was not held accountable.

    This case is a straightforward application of De Varon: because Florez-Meza’s guideline accountability was limited to the one transaction, the court evaluated her culpability within that transaction, where she negotiated terms, coordinated pickup, and facilitated the transfer.

  • United States v. Boyd, 291 F.3d 1274 (11th Cir. 2002): Used to emphasize the “considerable discretion” district courts have in the fact-intensive minor-role determination—supporting affirmance absent clear error.
  • United States v. Jews, 74 F.4th 1325 (11th Cir. 2023): Cited regarding the use of guideline commentary, noting it may be considered where its validity is not contested. The panel invoked Jews to justify relying on § 3B1.2’s commentary factors without revisiting broader commentary-validity debates.

3. § 2X1.1’s application to money-laundering conspiracies and interruption near completion

  • United States v. Khawaja, 118 F.3d 1454 (11th Cir. 1997): Established in this circuit that § 2X1.1 applies to conspiracies to commit money laundering. The panel used Khawaja as the gateway authority for applying § 2X1.1(b) to a § 1956(h) conviction.
  • United States v. Broughton, 689 F.3d 1260 (11th Cir. 2012): Cited for the elements of conspiracy to commit money laundering—agreement plus knowing/voluntary participation— supporting the conclusion that the conspiracy offense was fully formed and substantially executed.
  • United States v. Wade, 458 F.3d 1273 (11th Cir. 2006): Supplied the rule that failure to object to PSI factual allegations admits them for sentencing. This mattered because the PSI included Florez-Meza’s post-arrest statements about counting the money and transporting it to Colombia; those admitted facts helped show she believed she had nearly completed the necessary steps.
  • United States v. Geevers, 226 F.3d 186 (3d Cir. 2000): A persuasive authority cited to reinforce § 2X1.1’s background principle that interruption near completion forecloses the three-level reduction (except in early planning stages). The Eleventh Circuit used Geevers to bolster its reading of § 2X1.1’s background commentary.

B. Legal Reasoning

1. Why the minor-role reduction failed

The panel’s reasoning tracks § 3B1.2’s text and commentary and is anchored by United States v. De Varon. Although Florez-Meza emphasized that the overall conspiracy was “extensive” and her involvement spanned only three days, the district court had held her accountable only for the $740,000 transaction. That framing controlled the role analysis.

Within that transaction, the appellate court highlighted facts showing meaningful, not minor, participation: she met to negotiate the exchange, discussed logistics, negotiated an 11% fee, coordinated a third party to retrieve the money, and appeared at the pickup. These actions supported a finding that she exercised practical decision-making authority and discretion in executing the charged conduct. Under clear-error review, that fact-bound conclusion was not reversible.

The opinion also addresses the adequacy of findings: it reaffirmed that a district court need not make elaborate findings beyond the ultimate role determination, consistent with De Varon.

2. Why the § 2X1.1(b) reduction failed

Section 2X1.1(b) provides a three-level decrease for attempt/conspiracy in certain circumstances—generally when the defendant has not completed all acts she believed necessary for successful completion. But the guideline’s background commentary sharply limits the reduction where the offense was completed or was interrupted “on the verge of completion” by law enforcement intervention.

The court treated the arrest as an interruption at the final stage, not an early-stage abandonment. It relied on undisputed PSI facts (admitted under United States v. Wade) describing Florez-Meza’s plan to take the money home, count it, and then transport it to Colombia. Because she had already arranged the pickup and transfer and was effectively at the last step when police intervened, the court deemed her “on the cusp” of completing what she believed necessary. That placed the case within the “verge of completion” category, making the reduction unavailable.

C. Impact

Although unpublished and labeled “NOT FOR PUBLICATION,” the decision is a useful synthesis of existing Eleventh Circuit doctrine for two recurring guideline disputes in money-laundering prosecutions:

  • Role adjustments remain transaction-specific when relevant conduct is limited. Defendants held accountable for a single laundering event should expect courts to assess culpability primarily within that event rather than in the broader narcotics or trafficking enterprise.
  • § 2X1.1(b) reductions are hard to obtain in controlled operations that intervene late. In sting or controlled-delivery settings, where law enforcement allows substantial steps before arrest, courts are likely to find “verge of completion” and deny the three-level decrease.

Practically, the opinion underscores the sentencing importance of (1) how the government and probation define relevant conduct, and (2) whether the defendant can show meaningful incompleteness attributable to her own lack of progress rather than law-enforcement timing.

IV. Complex Concepts Simplified

  • Advisory guideline range: The Sentencing Guidelines produce a recommended sentencing range based on offense level and criminal history. Judges must calculate it correctly but may vary after considering 18 U.S.C. § 3553(a).
  • Relevant conduct: The conduct the sentencing court counts for guideline purposes. A defendant can be charged in a large conspiracy yet be sentenced based only on a narrower slice (here, one $740,000 transaction).
  • Minor-role reduction (§ 3B1.2(b)): A decrease for defendants who are less culpable than most participants in the criminal activity. In the Eleventh Circuit, the key comparison is often between the defendant and the conduct she is held accountable for, not the entire conspiracy.
  • Clear error vs. de novo review: Legal interpretations are reviewed “de novo” (fresh), but fact findings (like role in the offense) are reviewed for “clear error,” a highly deferential standard.
  • § 2X1.1(b) attempt/conspiracy reduction: A three-level reduction that can apply when the defendant did not complete all acts she believed necessary. It usually does not apply when police interrupt the offense at or near completion.
  • PSI admissions: If a defendant does not object to factual statements in the Presentence Investigation Report, those facts can be treated as admitted for sentencing.

V. Conclusion

United States v. Alejandra Florez-Meza reinforces two guideline principles as applied to money-laundering conspiracies: (1) minor-role analysis is anchored to the relevant conduct actually used to calculate the guideline range, and participation that drives the entire charged transaction will rarely qualify as “minor”; and (2) § 2X1.1(b)’s three-level reduction is generally unavailable when law enforcement intervenes at the “verge of completion,” even if the defendant’s ultimate objective (such as transporting funds abroad) is not fully realized due solely to arrest.