United States v. Santiago

SUMMARY ORDER

Defendant Sadrach Santiago pleaded guilty to a conspiracy to distribute five kilograms or more of cocaine, see 21 U.S.C. §§ 841(b)(1)(A), 846, and was sentenced principally to a below-Guidelines term of 144 months’ imprisonment. He appeals that sentence, arguing procedural error by the district court in the calculation of his Guidelines range and ineffective assistance of counsel at sentencing. We assume the parties’ familiarity with the facts and the record of prior proceedings, which we reference only as necessary to explain our decision.

1. Procedural Error

a. U.S.S.G. § 2D 1.1…