Background
Rafael Perdomo-Limus pleaded guilty to illegal reentry and was sentenced by the United States District Court for the Southern District of Texas. At sentencing, the district court imposed special supervised-release conditions as part of his sentence. Perdomo-Limus appealed, challenging the imposition of these conditions on the ground that they were not adequately pronounced during the sentencing hearing.
Specifically, Perdomo-Limus argued that the district court erred by failing to explicitly inquire on the record whether he had reviewed the presentence report and its appendix with his counsel prior to sentencing. He claimed this procedural deficiency rendered the sentencing pronouncement inadequate.
The Court’s Holding
The Fifth Circuit affirmed the district court’s judgment in full. The court held that Perdomo-Limus failed to demonstrate plain error in the district court’s oral pronouncement of his sentence. The appellate panel rejected his argument that an explicit on-the-record inquiry about presentence report review was required as a matter of course.
Applying the standard established in United States v. Villafana-Mondragon, 170 F.4th 360 (5th Cir. 2026), the court determined that a defendant challenging sentencing procedures must show clear error—not merely procedural irregularity or deviation from best practices. Perdomo-Limus failed to satisfy this burden, and the district court’s handling of the sentencing process remained within its discretion.
Key Takeaways
- Appellate review of sentencing procedures applies a plain-error standard requiring defendants to demonstrate clear error, not mere procedural deviation
- District courts are not required to make explicit on-the-record inquiries about presentence report review in every case
- The Villafana-Mondragon standard governs Fifth Circuit review of sentencing pronouncements
- Supervised-release conditions imposed at sentencing will be upheld absent a showing of plain error by the appellant
Why It Matters
This decision provides important guidance on the scope of procedural requirements at federal sentencing in the Fifth Circuit. It clarifies that while sentencing procedures must comply with applicable rules and constitutional requirements, courts need not engage in every conceivable inquiry on the record. The ruling reflects substantial deference to district court sentencing decisions and sets a high bar for appellate reversal based on procedural claims.
For defense practitioners and defendants in the Fifth Circuit, the decision underscores that sentencing appeals must rest on more than procedural irregularities. The case demonstrates that appellate courts will not overturn sentencing decisions on technical grounds absent a showing of plain error, which has implications for how defense counsel prepare clients for sentencing and evaluate appellate options in criminal cases.