United States v. Robles-Alvarez, No. 16-1222 (1st Cir. 2017)

First Circuit Court of Appeals Sentencing
In a large-scale cocaine trafficking appeal of a life sentence, the First Circuit reversed and remanded where the district court failed to address the defendant’s argument for a downward variance from his life sentence based on the sentences of his co-conspirators, which were considerably less, ranging from 46 to 210 months.  The First Circuit emphasized that while disparities generally are illustrated by reference to national disparities, they also can be established by reference to co-defendant sentences especially where, as here, the disparity was significant. The published opinion can be accessed here.
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