United States v. Plaza Estacio: Accuracy and Policy-Statement Fidelity in Amendment 821 Sentence-Reduction Proceedings

I. Introduction

The Eleventh Circuit’s unpublished decision in United States v. Carlos Adrian Plaza Estacio (No. 24‑13729, Nov. 21, 2025) addresses a now-frequent issue in federal sentencing practice: how district courts must approach motions for reduced sentences under 18 U.S.C. § 3582(c)(2) following Amendment 821 to the U.S. Sentencing Guidelines, especially for “zero-point offenders.”

The opinion is especially significant for three reasons:

It reinforces that district courts must adhere to the Sentencing Commission’s policy statements, particularly U.S.S.G. § 1B1.10, when adjudicating retroactive sentence-reduction motions.
It emphasizes that prior substantial assistance departures (under U.S.S.G. § 5K1.1 and 18 U.S.C. § 3553(e)) are not a reason against a further reduction; they are expressly treated as a special category that may be preserved through a comparable reduction below the amended range.
It clarifies that district courts abuse their discretion if they base § 3553(a) determinations on clearly erroneous factual assumptions—here, speculation that the defendant “benefitted” from unrecovered drugs when the undisputed record showed the drug quantity was fully and accurately captured in the original guideline calculation.

Although designated “Not for Publication” and therefore non-precedential in the Eleventh Circuit’s formal sense, the reasoning offers persuasive guidance for future § 3582(c)(2) proceedings, especially those involving Amendment 821 and maritime drug trafficking cases where contraband is jettisoned at sea.

II. Background of the Case

A. Facts of the Offense

In 2017, a U.S. Coast Guard maritime patrol aircraft (MPA) spotted a “go-fast vessel” (GFV) approximately 627 nautical miles south of Huatulco, Mexico, heading north with visible bales of cocaine stacked on its deck. The vessel carried three crew members, including defendant Carlos Adrian Plaza Estacio.

When the crew realized they had been detected, they began jettisoning their cargo overboard. The Coast Guard launched two assets:

One crew boarded and took control of the GFV.
Another crew searched the debris field for floating contraband.

Despite Ionscan swipes on the vessel indicating the presence of cocaine, no physical cocaine bales were recovered. However, a video recording of the jettisoning showed the crew discarding an estimated 200 to 220 kilograms of cocaine into the ocean.

B. Original Charges and Plea

Estacio was indicted on:

Count One: Conspiracy to distribute and possess with intent to distribute five kilograms or more of cocaine while on board a vessel subject to U.S. jurisdiction, in violation of 46 U.S.C. §§ 70503(a), 70506(a) and (b), and 21 U.S.C. § 960(b)(1)(B)(ii).
Count Two: Possession with intent to distribute five kilograms or more of cocaine while on board such a vessel, in violation of 46 U.S.C. §§ 70503(a), 70506(a), 18 U.S.C. § 2, and 21 U.S.C. § 960(b)(1)(B)(ii).

Under a written plea agreement, Estacio pleaded guilty to Count One, and Count Two was dismissed.

C. Original Guideline Calculation and Sentence

The Presentence Investigation Report (PSI) and the probation officer’s guideline calculation proceeded as follows:

Drug quantity: video evidence showed 200–220 kg of cocaine jettisoned.
Base offense level: 36 (for 150–less than 450 kg of cocaine) under U.S.S.G. § 2D1.1(c)(2).
Role adjustment: +2 levels because Estacio was the captain of the vessel (U.S.S.G. § 2D1.1(b)(3)(C)).
Safety valve reduction: −2 levels for meeting criteria under U.S.S.G. § 5C1.2.
Acceptance of responsibility: −3 levels under U.S.S.G. § 3E1.1(a) and (b).

This produced a total offense level of 33. With a criminal history score of zero, Estacio fell into Criminal History Category I, yielding an advisory guideline range of 135–168 months.

Before sentencing, the Government filed a motion under U.S.S.G. § 5K1.1 and 18 U.S.C. § 3553(e) for a two-level downward departure based on Estacio’s substantial assistance:

He provided truthful and timely information.
He was available to testify against his co-defendant.
His cooperation facilitated resolution of the co-defendant’s case.

The district court granted the motion and imposed:

108 months’ imprisonment (a substantial reduction from the 135–168 month range), and
five years’ supervised release.

D. Amendment 821 and the Zero-Point Offender Memorandum

In June 2024, a probation officer issued a memorandum identifying Estacio as eligible for a sentence reduction under Amendment 821 because he is a “zero-point offender”—that is, a defendant with zero criminal history points who satisfies specific criteria for a new two-level decrease.

Recalculating the guideline range under the amended Guidelines:

Amended offense level: 31 (instead of 33).
Criminal history: Category I (unchanged).
Amended guideline range: 108–135 months.

Applying a comparable two-level substantial assistance departure, the probation officer calculated an effective post-amendment guideline range of approximately 87–108 months.

Estacio then filed an unopposed motion for reduction of sentence under 18 U.S.C. § 3582(c)(2) and U.S.S.G. § 1B1.10, invoking Amendment 821.

E. The District Court’s Denial

The district court acknowledged that probation had confirmed Estacio’s eligibility but denied a reduction based on the 18 U.S.C. § 3553(a) factors, stating:

He had already received a downward departure and a “bottom end” sentence.
The smuggling operation “benefitted from jettisoning cocaine into the ocean as part of obstructive conduct.”
His guidelines “were lower because the cargo in part was not recovered.”
Further reduction would not “reflect the seriousness of the offense” or “promote respect for the law.”
Reducing the sentence would undermine deterrence.

Estacio appealed, arguing that the district court:

Ignored the Sentencing Commission’s policy statements,
Misapplied the § 3553(a) factors, and
Relied on clearly erroneous facts about the drug quantity and any supposed benefit from jettisoning cocaine.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit vacated the district court’s order and remanded for further proceedings.

Key holdings:

The district court abused its discretion at the second step of the § 3582(c)(2) analysis.
Its weighing of § 3553(a) was flawed because:
- It failed to properly consider the Sentencing Commission’s policy statement in U.S.S.G. § 1B1.10, particularly the treatment of substantial assistance departures, and
- It relied on clearly erroneous factual findings—namely, that Estacio’s guideline range had been artificially lowered due to only partial cargo recovery.

The panel underscored that:

Substantial assistance departures occupy a “special category” that may be preserved through a comparable reduction below the amended range.
There was no factual basis to conclude that Estacio’s original sentencing failed to account for the full quantity of cocaine; the PSI reasonably estimated 200–220 kg and used the 150–450 kg range, which neither party disputed.
By importing reasoning from a different case (also involving a defendant named Estacio) where only a fraction of the drugs were recovered and prosecuted, the district court introduced speculation inconsistent with the undisputed record here.

Accordingly, the Eleventh Circuit found the denial of relief improper and sent the matter back for a new exercise of discretion grounded in accurate facts and the relevant policy statements.

IV. Analysis

A. Legal Framework and Precedents Cited

1. § 3582(c)(2), the Two-Step Process, and Dillon

18 U.S.C. § 3582(c)(2) allows a court to reduce a term of imprisonment if:

The defendant was sentenced “based on a sentencing range that has subsequently been lowered” by the Sentencing Commission, and
The reduction is “consistent with applicable policy statements issued by the Sentencing Commission.”

The Supreme Court in Dillon v. United States, 560 U.S. 817 (2010), made clear that § 3582(c)(2) authorizes a limited modification of a sentence—not a full resentencing—and established a two-step process:

Eligibility step: Determine whether the applicable guideline range has been lowered by a retroactive amendment.
Discretion step: If eligible, decide whether, and to what extent, to reduce the sentence, considering:
- the § 3553(a) factors, and
- the relevant Sentencing Commission policy statements (notably U.S.S.G. § 1B1.10).

Dillon underscores that any reduction must be consistent with the Commission’s policy statements. That requirement is central in Plaza Estacio.

2. Caraballo-Martinez: Applying Dillon in the Eleventh Circuit

In United States v. Caraballo-Martinez, 866 F.3d 1233 (11th Cir. 2017), the Eleventh Circuit adopted Dillon’s framework:

Step one: determine eligibility (has the applicable range been lowered?).
Step two: exercise discretion under § 3553(a) and the policy statements.

Caraballo-Martinez also clarified the standard of review:

De novo review for legal and interpretive questions, including whether § 3582(c)(2) applies.
Abuse of discretion review for the district court’s decision to grant or deny a reduction where eligibility exists.

Plaza Estacio accepts that step one (eligibility) is satisfied and focuses on whether the district court abused its discretion at step two.

3. Giron: Defining Abuse of Discretion

The panel quotes United States v. Giron, 15 F.4th 1343 (11th Cir. 2021), for the abuse of discretion standard:

A district court abuses its discretion if it applies an incorrect legal standard, follows improper procedures in making its determination, or makes clearly erroneous factual findings.

The Giron standard is applied in Plaza Estacio to identify errors in both:

The district court’s treatment (or non-treatment) of the Commission’s policy statements, and
Its reliance on inaccurate factual assumptions about drug quantity and supposed benefit from jettisoned cocaine.

4. Marroquin-Medina: Substantial Assistance in § 3582(c)(2) Proceedings

In United States v. Marroquin-Medina, 817 F.3d 1285 (11th Cir. 2016), the Court explained that:

When the original sentence was below the guideline range due to substantial assistance, the district court considering a § 3582(c)(2) motion may, but is not required to, grant a “comparable” reduction below the amended range.
“Comparable” often means a similar percentage reduction or a similar degree of variance from the range.

Plaza Estacio relies on Marroquin-Medina to make two important points:

The district court is not compelled to replicate the substantial assistance departure when reconsidering the sentence.
However, it is error to treat the prior substantial assistance departure as a negative factor—something that weighs against granting any further reduction—especially where the policy statement in § 1B1.10 explicitly contemplates preserving such departures.

5. U.S.S.G. § 1B1.10 and the Substantial Assistance Exception

The decision quotes the critical provision of U.S.S.G. § 1B1.10 governing the extent of reductions. In general:

(A) Limitation.—Except as provided in subdivision (B), the court shall not reduce the defendant's term of imprisonment under 18 U.S.C. § 3582(c)(2) ... to a term that is less than the minimum of the amended guideline range ...

But there is a crucial exception:

(B) Exception for Substantial Assistance.—If the term of imprisonment imposed was less than the term of imprisonment provided by the guideline range ... pursuant to a government motion to reflect the defendant's substantial assistance ..., a reduction comparably less than the amended guideline range ... may be appropriate.

This structure makes substantial assistance departures a special category—the only routinely recognized basis for going below the bottom of the amended range in a § 3582(c)(2) proceeding. Plaza Estacio turns on the district court’s failure to appreciate this and its inversion of that logic.

6. The Earlier “Estacio” Case and Its Limits

The panel notes, in a pointed footnote, that the same district judge had recently decided a similar case involving another defendant with the same surname: United States v. Estacio, No. 8:21‑CR‑44‑WFJ‑TGW, 2024 WL 3771718 (M.D. Fla. Aug. 13, 2024), aff’d, No. 24‑12702, 2025 WL 1355234 (11th Cir. May 9, 2025).

In that earlier case (Henri Manrique Estacio):

The Coast Guard observed 10–12 bundles of cocaine on a low-profile vessel, but only 30 kg were recovered because the vessel was flooding.
The defendant was charged and sentenced based on that 30 kg.
The district court denied an Amendment 821 reduction on the ground that the original sentence already underestimated the seriousness of the offense because only a small fraction of the smuggled cocaine was recovered and used for sentencing.

The Eleventh Circuit had affirmed that denial in Henri Estacio’s case, accepting the judge’s reasoning that, in that context, refusing a further reduction could be tied to the offense’s true seriousness under § 3553(a).

In Plaza Estacio, however, the panel explains why that reasoning is “inoperable”:

Here, video showed an estimated 200–220 kg being jettisoned.
The guideline calculation explicitly used the 150–450 kg range consistent with that estimate.
No party disputed the quantity in the PSI, and there was no indication that Estacio was sentenced on less cocaine than he actually smuggled.

Thus, importing the “under-punished quantity” rationale from the earlier Estacio case had no factual foundation and contributed directly to the abuse of discretion.

B. The Court’s Legal Reasoning

1. Proper Step-One Determination: Eligibility Under Amendment 821

The panel accepts, implicitly, that step one of the Dillon–Caraballo-Martinez framework is satisfied:

Amendment 821 is retroactive.
Estacio is a “zero-point offender” qualifying for a two-level reduction under the revised guidelines.
The probation officer correctly recalculated his total offense level as 31, preserving Criminal History Category I, producing an amended range of 108–135 months.

Estacio was originally sentenced based on a range of 135–168 months, so his “sentencing range ... has subsequently been lowered” within the meaning of § 3582(c)(2). That opens the door to the step-two discretionary analysis.

2. The Step-Two Error: Mishandling Substantial Assistance and Policy Statements

At step two, the court must consider:

The § 3553(a) factors, and
Relevant policy statements, particularly U.S.S.G. § 1B1.10.

The Eleventh Circuit identifies a fundamental problem: the district court mentioned that Estacio had “already got a downward departure,” but:

It never acknowledged that the downward departure was granted specifically for substantial assistance, and
It treated the existence of that departure and the “bottom end” sentence as a reason to deny any further reduction.

This treatment clashes with § 1B1.10(b)(2)(B), which—in effect—privileges substantial assistance departures: they are the express exception to the otherwise rigid “no lower than the bottom of the amended range” rule.

The panel’s logic is:

The Commission has singled out substantial assistance as a category for which courts may go below the amended range to maintain a “comparably less” sentence.
By ignoring this special status and instead using the prior 5K1.1 reduction as an argument against further reduction, the district court failed to respect the structure and purpose of § 1B1.10.
At a minimum, the district court needed to grapple with why a substantial assistance departure was appropriate at the original sentencing “but is now inappropriate in light of Amendment 821.” The order did not do this.

While Marroquin-Medina confirms that courts are not obligated to carry forward the same degree of reduction, Plaza Estacio underscores that courts must:

Recognize that substantial assistance falls into a preferred category under the policy statement, and
Not treat the existence of a 5K1.1 departure as an automatic bar or as a negative factor under § 3553(a).

3. The Step-Two Error: Clearly Erroneous Findings About Drug Quantity

The second, equally significant problem lies in the factual premise that Estacio:

“benefitted from jettisoning cocaine into the ocean,” and
had “guidelines ... lower because the cargo in part was not recovered.”

The record, however, was:

Undisputed that all the cocaine was jettisoned and none was recovered physically.
Clear that the PSI used an estimated 200–220 kg based on video evidence.
Clear that the guideline range of 150–450 kg fully captured that estimate.
Unchallenged by either party—no objections to the drug-quantity finding.

Thus, the suggestion that Estacio enjoyed a “lower guideline” because only part of the cargo was accounted for is factually wrong. As the panel notes:

If the video-based estimate were deemed uncertain, it could just as plausibly suggest a lower actual quantity than a higher one; speculation in either direction is impermissible.
The record gave the court no basis to conclude that Estacio’s original sentence under-reflected the true quantity.

Because § 3553(a) determinations must rest on accurate facts, relying on this speculation constitutes a clearly erroneous factual finding under Giron, and thus an abuse of discretion.

4. Importing Reasoning from a Factually Distinct Case

The panel’s footnote about the earlier Estacio case highlights an important limitation:

In Henri Estacio’s case, the court’s belief that the sentence reflected less than 10% of the smuggled cocaine had support in specific record facts: observable (but unrecovered) additional bales and a flooding vessel that prevented a full search.
In Carlos Plaza Estacio’s case, there was no such discrepancy between the observed and the estimated/charged quantities. The estimation and guideline range already covered the smuggled amount.

By effectively transplanting reasoning appropriate to the prior case into this one without factual foundation, the district court artificially “corrected” a perceived under-punishment that did not exist. The Eleventh Circuit labels this “particularly troubling,” underscoring how carefully district courts must distinguish between cases, especially in high-volume maritime prosecutions with similar fact patterns.

C. Impact of the Decision

1. For Zero-Point Offenders and Amendment 821 Litigation

Amendment 821 has generated substantial litigation by defendants with zero criminal history points seeking retroactive reductions. Plaza Estacio offers several practical signals for such cases:

Eligibility determination alone is not enough; district courts retain broad discretion at step two—but that discretion is bounded by:
- Faithful adherence to U.S.S.G. § 1B1.10, and
- Factually accurate application of § 3553(a).
Where the original sentence included a substantial assistance departure, courts should:
- Expressly identify that fact, and
- Explicitly analyze whether a “comparable” reduction below the amended range is appropriate.
Using the existence of a 5K1.1/§ 3553(e) departure as a blanket justification for denying further relief risks reversal if the court does not engage with § 1B1.10’s special treatment of substantial assistance.

2. For Maritime Drug Cases and Jettisoned Contraband

In maritime interdiction cases under the MDLEA (46 U.S.C. §§ 70503, 70506), contraband is often jettisoned or destroyed before seizure. Plaza Estacio has implications here:

Courts may rely on reasonable estimates of drug quantity (such as video or radar evidence) in the original sentencing, even where no drugs are physically recovered.
At the § 3582(c)(2) stage, however, courts cannot:
- Speculate that the defendant “benefitted” from incomplete recovery absent evidence that the guideline calculation reflected a lower quantity than reasonably estimated and proved, nor
- Retroactively “correct” perceived underestimation by denying an otherwise appropriate reduction based on conjecture.

In short, Plaza Estacio discourages “back-door” adjustments to original sentencing judgments via § 3582(c)(2) denials, especially where no party challenged the PSI’s drug quantity and the sentencing court accepted it at the time.

3. Structuring Future § 3582(c)(2) Orders in the Eleventh Circuit

Although non-precedential, Plaza Estacio is likely to influence how district judges in the Eleventh Circuit write orders in retroactive-amendment cases:

Orders will likely:
- Explicitly acknowledge whether a substantial assistance departure was given,
- Reference § 1B1.10(b)(2)(B) where relevant, and
- Explain why a comparable reduction is or is not warranted.
Courts will need to ensure factual findings are tethered to the record, without extrapolation from similar but factually distinct cases.
Where the Government does not oppose a reduction and probation affirms eligibility, district courts will need especially clear, record-based reasons to deny relief.

4. Deterrence and Respect for Law Under § 3553(a)

The district court invoked deterrence and respect for the law to deny relief. Plaza Estacio does not hold that those considerations can never justify denying a reduction. Instead, the opinion teaches:

Deterrence and seriousness-of-offense concerns must be applied to actual, record-based facts, not to conjectured benefits (such as hypothetical undercounted drug quantities).
If a sentence already properly reflects the reasonably proven drug quantity and seriousness of the smuggling operation, it is improper to deny an amendment-based reduction on the theory that the original sentence was secretly too low all along.

V. Complex Concepts Simplified

1. What Is a “Zero-Point Offender” Under Amendment 821?

A “zero-point offender” is a defendant who:

Has no criminal history points under the Guidelines (i.e., a very limited or nonexistent record), and
Meets additional criteria showing relatively low recidivism risk (for example, no aggravating conduct of certain types).

Amendment 821 introduced a general rule that qualifying zero-point offenders receive a two-level reduction in their offense level, on the premise that people with truly clean records are less likely to reoffend and may deserve slightly lower sentences.

2. What Is a Downward Departure for Substantial Assistance?

A downward departure is a discretionary reduction from the guideline range based on specific factors identified in the Guidelines or statutes.

A departure for substantial assistance occurs when:

The defendant meaningfully helps the Government (e.g., by providing information, testifying against co-defendants).
The Government files a motion under U.S.S.G. § 5K1.1 (and, if below any statutory mandatory minimum, under 18 U.S.C. § 3553(e)).
The court then has authority to sentence below the guideline range (and, via § 3553(e), below a mandatory minimum).

In Plaza Estacio, this is what reduced the original sentence from a guideline range of 135–168 months to 108 months.

3. U.S.S.G. § 1B1.10 and “Comparable” Reductions

Section 1B1.10 governs how courts implement retroactive guideline amendments. The default rule: the court cannot go below the bottom of the amended range. But if the original sentence was below the old range because of substantial assistance, the court may go below the amended range by a roughly similar amount (“comparably less”).

In practice, this often means:

Either repeating the same number of months below the new range, or
Applying a similar percentage reduction from the new range.

4. Abuse of Discretion and Clearly Erroneous Facts

An appellate court will not overturn a district court’s discretionary decision just because it would have decided differently. But it will intervene if:

The wrong legal rule was applied, or
The decision relied on a key factual finding that has no support in the record and is clearly mistaken.

In Plaza Estacio, the mistaken belief that the original guideline range was artificially low because “only part” of the drugs were captured by the PSI crossed that line into “clearly erroneous” territory.

VI. Conclusion

United States v. Plaza Estacio reinforces several important principles for post-sentencing reductions under 18 U.S.C. § 3582(c)(2) in the era of Amendment 821:

Policy statements matter. District courts must faithfully apply U.S.S.G. § 1B1.10, especially its specific treatment of substantial assistance departures. They may not convert the fact of a prior 5K1.1 reduction into a categorical reason to deny further relief.
Facts must be accurate. § 3553(a) analysis must be grounded in the record. Suppositions that a defendant “benefitted” from unrecovered contraband are improper where the PSI, supported by evidence and undisputed, already captured the full reasonably estimated quantity.
Substantial assistance is a special category. The Sentencing Commission has singled out such departures as the only routine basis for going below the bottom of the amended range. Courts retain discretion but must engage with, rather than ignore or invert, that policy.
§ 3582(c)(2) is not an avenue to rewrite history. It cannot be used to retroactively “correct” a perceived under-punishment when the original sentence was based on accurate, unchallenged facts. Nor can it be denied on speculative grounds disconnected from the record.

Although unpublished, the decision provides a detailed roadmap for how courts should navigate sentence-reduction motions following Amendment 821, particularly in drug cases involving zero-point offenders and maritime interdictions. It underscores that even in streamlined, non-argument appeals, the Eleventh Circuit will insist on fidelity both to the Sentencing Commission’s guidance and to the factual record.