The U.S. Court of Appeals for the Eleventh Circuit affirmed the conviction and sentence of Kevin Valdez in a drug conspiracy case involving the importation of cocaine from Puerto Rico to Florida through the United States Postal Service.
In a per curiam opinion filed Jan. 12, 2026, the three-judge panel consisting of Circuit Judges Newsom, Grant, and Brasher rejected Valdez's challenge to the factual findings underlying the district court's Guidelines range calculation and sentence. The court's brief ruling in *United States v. Kevin Valdez* (11th Cir. 2026) upheld the lower court's decision without oral argument.
Valdez was convicted as a "high-level dealer" in a conspiracy that used the U.S. Postal Service to transport cocaine and other narcotics from Puerto Rico into Florida. According to court documents, Valdez was responsible for the possession and distribution of 764 grams of cocaine, a substantial quantity that placed him in a leadership role within the trafficking operation.
The defendant pleaded guilty to one count of conspiracy to distribute or possess with intent to distribute cocaine under 21 U.S.C. §§ 846 and 841(b)(1)(C). The case originated in the U.S. District Court for the Middle District of Florida, where Valdez was sentenced following his guilty plea.
At sentencing, the district court applied a two-level enhancement to Valdez's sentence based on firearms found in his coconspirators' homes. The enhancement falls under U.S. Sentencing Guidelines § 2D1.1(b)(1), which allows for increased penalties when firearms are involved in drug trafficking offenses.
The district court justified the firearms enhancement by noting the substantial nature of the drug operation and Valdez's role as a distributor. "When you're dealing with this amount of cocaine and you're a distributor yourself, in light of the facts here, I think it is reasonably foreseeable that firearms would be used," the court said during sentencing proceedings.
This reasoning reflects established precedent that allows courts to enhance sentences for drug offenses when firearms possession by coconspirators was reasonably foreseeable to the defendant, even if the defendant did not personally possess weapons. The enhancement recognizes the inherent danger and violence associated with large-scale drug trafficking operations.
Valdez's appeal focused on challenging the factual findings that supported the district court's Guidelines calculation. However, the Eleventh Circuit found no error in the lower court's analysis or application of the sentencing guidelines. The appeals court's affirmance suggests that the district court properly applied the relevant legal standards and that substantial evidence supported its factual determinations.
The case highlights ongoing federal efforts to combat drug trafficking operations that exploit the postal system to transport narcotics between Puerto Rico and the mainland United States. Puerto Rico has long served as a transshipment point for South American cocaine destined for U.S. markets, with traffickers often using mail services to avoid detection at traditional border crossings.
The use of the U.S. Postal Service for drug trafficking presents unique challenges for law enforcement, as postal inspectors must balance mail privacy protections with the need to intercept illegal shipments. Federal prosecutors have increasingly targeted these mail-based trafficking networks, often resulting in conspiracy charges that can encompass multiple defendants across different states.
The firearms enhancement applied in Valdez's case reflects the federal government's policy of imposing harsher penalties when drug trafficking involves weapons, even when defendants do not directly possess firearms themselves. This approach recognizes that large-scale drug operations inherently involve the risk of violence and that all participants share responsibility for the dangerous nature of the enterprise.
Valdez's case was designated for the Non-Argument Calendar, indicating that the Eleventh Circuit determined oral arguments were not necessary to resolve the appeal. This procedural designation is typically used for cases where the legal issues are straightforward or where the appellant's arguments lack merit.
The brief per curiam opinion, marked "NOT FOR PUBLICATION," means the decision will not be published in the official reporter and has limited precedential value. However, it still represents binding law for the parties involved and reflects the Eleventh Circuit's approach to similar sentencing challenges in drug conspiracy cases.
The affirmance of Valdez's sentence reinforces federal courts' willingness to uphold substantial penalties for high-level participants in drug trafficking conspiracies, particularly those involving interstate transportation of narcotics. The decision also demonstrates judicial support for sentencing enhancements based on the foreseeable criminal conduct of coconspirators, even when defendants did not personally engage in all aspects of the criminal enterprise.
For defense attorneys handling similar cases, the ruling underscores the difficulty of successfully challenging Guidelines calculations on appeal, particularly when district courts provide reasoned explanations for their sentencing decisions based on the specific facts and circumstances of each case.
