The U.S. Court of Appeals for the First Circuit affirmed a 60-month prison sentence for Christian Del-Valle-Camacho, who escaped from a court-ordered re-entry program and was found in possession of firearms and ammunition. In a decision issued Jan. 14, 2026, the appeals court rejected Del-Valle-Camacho's challenge to what he argued was an unreasonable 19-month upward sentencing variance.
Circuit Judge Dunlap, writing for the three-judge panel, held that the U.S. District Court for the District of Puerto Rico provided sufficient justification for the upward variance based on the large amount of ammunition and number of magazines found in Del-Valle-Camacho's possession.
The case stems from events that occurred while Del-Valle-Camacho was serving time in a residential re-entry facility following his incarceration for a federal drug trafficking conviction. The defendant had been ordered by the court to complete his sentence at the facility as part of his supervised release.
On Nov. 2, 2023, Del-Valle-Camacho was returning to the facility from an approved work pass when a drive-by shooting occurred in the area. The incident led to his flight from the re-entry program, violating the terms of his court-ordered placement.
Authorities subsequently discovered that Del-Valle-Camacho was in possession of firearms and ammunition, leading to additional federal charges. As a convicted felon, his possession of firearms violated federal law prohibiting felons from possessing firearms or ammunition.
Del-Valle-Camacho was ultimately charged with two federal offenses: escaping from the judicially mandated re-entry program and being a felon in possession of a firearm and ammunition. The district court imposed concurrent 60-month prison sentences for both charges.
On appeal, Del-Valle-Camacho challenged both the procedural and substantive reasonableness of his sentence. He argued that the district court failed to provide an adequate explanation for imposing the 19-month upward variance from what would have been the standard sentencing guidelines range.
Defense attorney Jason González-Delgado represented Del-Valle-Camacho in the appeal, while Assistant U.S. Attorney Julia M. Meconiates argued the case for the government alongside U.S. Attorney W. Stephen Muldrow and Assistant U.S. Attorney Juan Carlos Reyes-Ramos.
In rejecting the appeal, the First Circuit found that the district court had provided sufficient reasoning for the upward variance. The appeals court specifically noted that the trial judge's decision was justified by the large quantity of ammunition and number of magazines found in Del-Valle-Camacho's possession.
The decision represents an application of federal sentencing guidelines that allow judges to impose sentences above the standard range when specific factors warrant enhanced punishment. Courts must provide adequate explanations for such variances, and appellate courts review these decisions for both procedural and substantive reasonableness.
Procedural reasonableness requires that the sentencing court follow proper procedures in calculating and imposing the sentence, while substantive reasonableness examines whether the sentence imposed is appropriate given all the circumstances of the case.
The First Circuit's affirmance indicates that trial courts have significant discretion in imposing upward variances when supported by specific factual findings. The quantity of contraband possessed by a defendant can serve as a legitimate basis for enhanced sentencing under federal guidelines.
The case also highlights the serious consequences that can result from violating the terms of supervised release or court-ordered residential programs. Re-entry programs are designed to help federal inmates transition back into society while completing their sentences under supervision.
Violating the terms of such programs can result in additional criminal charges and significantly longer prison sentences, as demonstrated in Del-Valle-Camacho's case. The concurrent nature of his sentences means he will serve both terms simultaneously rather than consecutively.
The First Circuit panel that decided the case included Chief Judge Barron and Circuit Judges Aframe and Dunlap. The decision was issued following appeals from the District Court for the District of Puerto Rico, where U.S. District Judge Francisco A. Besosa presided over the original sentencing.
Federal sentencing guidelines provide structured frameworks for determining appropriate punishment, but trial judges retain discretion to impose sentences above or below the guidelines range when circumstances warrant such departures. Appellate courts generally defer to trial court sentencing decisions unless they are clearly unreasonable.
The affirmance of Del-Valle-Camacho's sentence reinforces federal courts' authority to impose enhanced punishment for defendants who compound their original offenses with additional criminal conduct, particularly when involving firearms possession by prohibited persons.
With the appeal exhausted at the circuit court level, Del-Valle-Camacho's conviction and 60-month sentence stand. The defendant could potentially seek review by the Supreme Court, though the high court accepts only a small percentage of petitions for certiorari.