United States v. Alejandro Ceja-Prado

On April 26, 2001, a man claiming to be Alejandro Ceja-Prado was arrested and charged with entering into a conspiracy to sell methamphetamine. Ceja-Prado pled guilty to the offense, and was sentenced to 151 months of imprisonment with three years of supervised release. Although Ceja-Prado testified during his plea colloquy that he was twenty-one when the crime was committed, he now presents evidence purporting to establish that he was a juvenile at the time of the crime. If this is true, there is presently, and was at the time of the conviction, no federal jurisdiction over Ceja-Prado’s case. The Federal Juvenile Delinquency Act, 18 U.S.C. §§ 5031 et seq., provides that federal courts have no jurisdiction over certain prosecutions for acts of juvenile delinquency unless the cases have been certified for prosecution by the Attorney General or his specified representatives, and no such certification has been lodged in this case. Because every federal court has a continuing obligation to ensure that it possesses subject-matter jurisdiction, we remand for an evidentiary hearing on the jurisdictional facts put in question by the newly presented evidence.

I

The defendant, who…