The U.S. Court of Appeals for the Eleventh Circuit affirmed a 20-year prison sentence for a Florida man convicted of large-scale fentanyl distribution, rejecting his claim that the district court failed to properly consider his role in the drug conspiracy.
Eddy Alexander Salinas appealed his total sentence of 240 months' imprisonment for two counts of distribution of 40 grams or more of fentanyl and one count of conspiracy to possess 400 grams or more of fentanyl with intent to distribute. The case originated in the U.S. District Court for the Southern District of Florida.
Salinas argued that his sentence was procedurally unreasonable because the district court failed to consider and weigh all relevant conduct when it denied his request for a two-level minor-role reduction under U.S. Sentencing Guidelines Section 3B1.2. Under federal sentencing guidelines, defendants who play a minimal or minor role in criminal activity may receive reduced sentences.
The government countered that Salinas, classified as a "career offender" under federal guidelines, was categorically ineligible to receive the minor-role reduction. Career offender status applies to defendants with prior convictions for crimes of violence or controlled substance offenses, resulting in enhanced sentencing ranges.
In a per curiam opinion filed Feb. 4, 2026, the three-judge panel consisting of Circuit Judges Rosenbaum, Newsom, and Grant sided with the government. The court held that "minor role adjustments are not available to [career offenders] sentenced under § 4B1.1," which "by its express terms, only authorizes an adjustment based on acceptance of responsibility."
The appeals court cited *United States v. Jeter*, a 2003 Eleventh Circuit precedent that established career offenders cannot receive minor-role reductions under the federal sentencing guidelines. In *Jeter*, the court held that Section 4B1.1 of the guidelines, which governs career offender sentencing, permits only adjustments for acceptance of responsibility, not for minor role in the offense.
The district court had found Salinas to be a career offender, which significantly enhanced his potential sentence range under the federal guidelines. Career offender status typically results in much higher guideline ranges than would otherwise apply to the underlying drug offenses.
The case highlights the severe penalties facing repeat drug offenders under federal law, particularly those involving fentanyl distribution. Federal prosecutors have increasingly focused on fentanyl cases as the synthetic opioid has become a leading cause of overdose deaths nationwide. The Drug Enforcement Administration considers fentanyl 50 to 100 times more potent than morphine.
The charges against Salinas involved substantial quantities of fentanyl. Distribution of 40 grams or more of fentanyl carries a mandatory minimum sentence of five years in federal prison, with a maximum of 40 years. Conspiracy to possess 400 grams or more with intent to distribute carries even stiffer penalties, with a mandatory minimum of 10 years and a maximum of life imprisonment.
The career offender enhancement significantly increased Salinas's exposure. Under Section 4B1.1 of the sentencing guidelines, career offenders face enhanced base offense levels and criminal history categories, often resulting in guideline ranges at or near the statutory maximum penalties.
The Eleventh Circuit's decision reflects the limited options available to career offenders seeking sentence reductions under federal guidelines. While defendants without prior convictions may argue for minor-role reductions based on their limited participation in criminal conspiracies, career offenders are restricted to adjustments for acceptance of responsibility, typically achieved by pleading guilty and demonstrating remorse.
The case was decided on the non-argument calendar, meaning the court resolved the appeal based on written briefs without oral arguments. Such treatment is typical for appeals presenting straightforward legal questions or where existing circuit precedent clearly governs the outcome.
The ruling reinforces federal courts' strict application of career offender enhancements in drug cases. Defense attorneys representing repeat offenders in drug cases face significant challenges in securing reduced sentences, as the guidelines severely limit available adjustments for career offenders.
The Southern District of Florida, where Salinas was originally sentenced, has been a focal point for federal drug prosecutions, particularly cases involving trafficking routes through South Florida ports and airports. The region serves as a major entry point for illegal drugs entering the United States from Latin America.
Salinas's 240-month sentence represents the substantial penalties federal defendants face for large-scale fentanyl distribution, particularly those with prior criminal histories. The case demonstrates how career offender enhancements can effectively eliminate sentencing departures that might otherwise be available to first-time or minimal participants in drug conspiracies.
The decision provides clarity for future cases involving career offenders seeking minor-role reductions, confirming that such adjustments remain categorically unavailable under current federal sentencing guidelines for repeat offenders classified under Section 4B1.1.