UNITED STATES OF AMERICA v. LEONEL MILLER HINOJOSA, JR - Articles

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UNITED STATES OF AMERICA v. LEONEL MILLER HINOJOSA, JR

Posted by: Azya Thornton on May 30, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Scott Graham, SCOTT GRAHAM PLLC, Portage, Michigan, for Appellant.

Attorneys 2: ON BRIEF: Kathryn M. Dalzell, UNITED STATES ATTORNEY’S OFFICE, Grand Rapids, Michigan, for Appellee.

Judge(s): SUTTON, Chief Judge; BATCHELDER and MURPHY, Circuit Judges

Court Appealed: United States District Court for the Western District of Michigan at Grand Rapids

MURPHY, Circuit Judge. A district court originally sentenced Leonel Hinojosa to 240 months in prison for shooting a man during a robbery. But we vacated his sentence because the record left unclear whether the court properly used one of Hinojosa’s prior convictions to calculate his guidelines range. See United States v. Hinojosa, 67 F.4th 334, 343–47 (6th Cir. 2023). The court could rely on this prior conviction only if it “resulted in” Hinojosa’s incarceration during “any” time in the 15 years before he committed his current offenses. U.S.S.G. § 4A1.2(e)(1). On remand, the government presented additional evidence about Hinojosa’s criminal history. The record now shows that—but for this prior conviction— Hinojosa would have served less time in prison during the guideline’s 15-year “lookback” period. And we hold that this “but for” causal connection between the prior conviction and the extra incarceration satisfies the guideline’s “resulted in” language. Apart from this question, the district court also reasonably sentenced Hinojosa to 240 months due to his history of violence. This time, then, we affirm his sentence.

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