United States v. Maldonado-Arce: Clarifying Plain-Error Vacatur When Sentencing Relies on Chronologically Impossible Facts

Introduction

United States v. Rodrigo Maldonado-Arce, No. 24-12306 (11th Cir. July 28, 2025), concerns a 180-month sentence imposed for drug and firearm offences on an undocumented defendant whose advisory Guideline range was 120–135 months. The district judge upwardly varied, expressly stressing that the defendant had “already been deported once,” “come back,” and then committed the instant crimes. On appeal, the Eleventh Circuit confronted two questions:

Did the district court commit procedural error by relying on clearly erroneous facts?
If so, did that error satisfy the stringent requirements of plain-error review, given that the defence had not objected?

Vacating and remanding for resentencing, the panel clarified how a sentencing court’s reliance on factually impossible chronology can satisfy all four plain-error prongs and demand correction even where the misstatement originated in an unchallenged Presentence Investigation Report (PSI).

Summary of the Judgment

The Court held that the district judge’s determination that Mr. Maldonado-Arce had re-entered the United States after a May 2022 deportation and then committed January 2022 offences was clearly erroneous and violated due-process protections against sentencing on false premises.
Because the error was not brought to the district court’s attention, review proceeded under plain-error standards (error, plainness, effect on substantial rights, and impact on the integrity of proceedings).
All four prongs were met:
- Error: reliance on an impossible timeline.
- Plainness: longstanding rule that sentences may not rest on false information.
- Substantial rights: reasonable probability that—absent the error—the court would have imposed no upward variance.
- Integrity of proceedings: unnecessary deprivation of liberty undermines public confidence, echoing Rosales-Mireles.
The Court therefore vacated the sentence and remanded, declining to reach substantive-reasonableness arguments.

Analysis

A. Precedents Cited and Their Influence

Gall v. United States, 552 U.S. 38 (2007): Provided the modern template for reviewing sentences for procedural reasonableness, explicitly prohibiting reliance on clearly erroneous facts. Gall’s language framed the panel’s identification of error.
United States v. Corbett, 921 F.3d 1032 (11th Cir. 2019): Defined preservation requirements; used to hold that the objection was not preserved, triggering plain-error review.
United States v. Aguillard, 217 F.3d 1319 (11th Cir. 2000): Supplied the standard for applying plain-error review to unpreserved sentencing challenges.
Rosales-Mireles v. United States, 585 U.S. 129 (2018): Emphasised that unwarranted deprivations of liberty undermine the integrity of judicial proceedings; critical to satisfying the fourth prong.
Additional Eleventh Circuit cases (Philidor, Shelton, Jones, Bankston): Collectively illustrated when factual mistakes, guideline miscalculations, or statutory-maximum errors warrant vacatur under plain-error doctrine.

B. Legal Reasoning of the Court

Identification of Error: The PSI notation “Disposition: Deported (May 2022)” was read by the sentencing judge as proof that the defendant had been removed before the January 2022 drug and firearm conduct. But the PSI unambiguously dated the offences to January 2022; thus, the deportation could not precede them. The panel deemed this “chronologically impossible,” satisfying the “clearly erroneous” standard.
Plainness: Reliance on false information at sentencing has long been forbidden; therefore, the mistake was obvious under existing law.
Effect on Substantial Rights: The sentencing judge explicitly used the erroneous deportation-and-return narrative to justify an upward variance (180 vs. 120 months). The panel concluded there was a reasonable probability of a lower sentence but for the error.
Integrity of Proceedings: Invoking Rosales-Mireles, the panel observed that liberty interest and public confidence require correction when a sentence is demonstrably premised on falsehoods.

C. Impact on Future Litigation and Sentencing Practice

Reaffirms that chronology matters: Even minor chronological misreadings—if relied on—will justify vacatur.
Signals that courts of appeals will closely scrutinise upward variances where factual predicates are tenuous or lifted uncritically from the PSI.
Probation offices are put on notice: Inaccurate or ambiguous PSI entries risk reversal and additional proceedings.
Clarifies for practitioners that a defendant need not show the error altered the guideline range; showing “reasonable probability” of a different sentence suffices under Jones.
Contributes to Eleventh Circuit precedent on plain-error fourth-prong discretion, aligning with Supreme Court guidance that unwarranted incarceration damages the justice system’s reputation.

Complex Concepts Simplified

Procedural vs. Substantive Reasonableness: Procedural concerns how the sentence was reached (errors in calculation, reliance on false facts); substantive looks at length of sentence in light of 18 U.S.C. § 3553(a) factors.
Plain-Error Review: Four-part test applied when an issue was not raised below—(1) error, (2) plainness, (3) effect on substantial rights, (4) impact on fairness/integrity/public reputation. All must be met.
Presentence Investigation Report (PSI): A document prepared by probation officers summarising the defendant’s background; courts may rely on unobjected-to factual statements therein.
Upward Variance: A sentence above the advisory Guideline range, justified under § 3553(a) factors.
Due Process at Sentencing: The Fifth Amendment guarantees that punishment not be based on materially false or unreliable information.

Conclusion

The Eleventh Circuit’s decision in United States v. Maldonado-Arce reinforces a fundamental principle: a sentencing court must never rest punishment on impossible or erroneous factual assumptions. Even when defence counsel fails to object, the appellate court will intervene where the record shows: (1) a manifest factual error, (2) explicit reliance on that error, and (3) a reasonable probability of a different outcome. The ruling thus protects defendants’ liberty interests, ensures accurate fact-finding, and underscores the continued vitality of plain-error correction in federal sentencing jurisprudence.