# United States v. Villareal

> Court of Appeals for the Fifth Circuit · September 16, 2025

URL: https://www.frixlaw.com/law-library/cases/11139040

## Case

- **Court:** Court of Appeals for the Fifth Circuit
- **Decided:** September 16, 2025
- **Precedential status:** Unpublished
- **Opinion:** Opinion
- **Nature of suit:** Direct Criminal
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

Case: 24-30765 Document: 59-1 Page: 1 Date Filed: 09/16/2025

United States Court of Appeals
for the Fifth Circuit
____________
United States Court of Appeals
Fifth Circuit
No. 24-30765
Summary Calendar FILED
____________ September 16, 2025
Lyle W. Cayce
United States of America, Clerk

Plaintiff—Appellee,

versus

Juan Villareal,

Defendant—Appellant.
______________________________

Appeal from the United States District Court
for the Middle District of Louisiana
USDC No. 3:22-CR-68-2
______________________________

Before King, Haynes, and Ho, Circuit Judges.
Per Curiam: *
Juan Villareal appeals the sentence imposed following his guilty plea
convictions for one count of conspiracy to distribute and to possess with the
intent to distribute five kilograms or more of cocaine and heroin and two
counts of unlawful use of communication facilities. He argues that the
district court erred by denying his request for a two-level reduction, pursuant

_____________________
*
This opinion is not designated for publication. See 5th Cir. R. 47.5.
Case: 24-30765 Document: 59-1 Page: 2 Date Filed: 09/16/2025

No. 24-30765

to U.S.S.G. § 2D1.1(b)(18), in light of the district court’s finding that he
failed to meet the safety valve criteria, as stated in U.S.S.G. § 5C1.2(a)(4).
He asserts that the district court misinterpreted § 5C1.2(a)(4). He contends
that he meets the safety valve criteria because he managed or supervised only
one person, not “others,” as stated in § 5C1.2(a)(4). This court reviews the
district court’s interpretation and application of the Sentencing Guidelines
de novo and factual findings for clear error. United States v. Gomez-Alvarez,
781 F.3d 787, 791 (5th Cir. 2015); see United States v. Vasquez, 161 F.3d 909,
910 (5th Cir. 1998).
We “consistently held that a § 3B1.1 enhancement alone is sufficient
to preclude safety-valve relief.” United States Morales, 122 F.4th 590, 597
(5th Cir. 2024). In doing so, this court has repeatedly interpreted
§ 5C1.2(a)(4) to indicate that the defendant does not meet the safety valve
criteria if he has received an aggravating role adjustment pursuant to § 3B1.1,
without analysis of corresponding guidelines commentary or the facts
warranting the adjustment. See, e.g., United States v. Flanagan, 80 F.3d 143,
147 (5th Cir. 1996). Accordingly, the district court did not err in its
interpretation of § 5C1.2(a)(4) or clearly err in its finding that Villareal failed
to establish that he met the safety valve criteria. See, e.g., Flanagan, 80 F.3d
at 145-47. Because Villareal did not meet the safety valve criteria, the district
court did not clearly err in its finding that he did not qualify for a two-level
reduction pursuant to § 2D1.1(b)(18). See Gomez-Alvarez, 781 F.3d at 791.
AFFIRMED.

2

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11139040. Public record. Not legal advice.