United States v. Brijido Mejia-Pimental

This case provides the occasion to explore the parameters of the statutory safety valve, which grants relief from certain mandatory minimum sentences when five criteria are met. See 18 U.S.C. § 3553®. We have previously decided that the fifth factor, which requires a defendant to “truthfully provide[]” all his knowledge about the crime to the Government before sentencing, see § 3553(f)(5), is aimed at defendants “who ‘have made a good-faith effort to cooperate with the government.’ ” United States v. Shrethsa, 86 F.3d 935, 940 (9th Cir.1996) (quoting United States v. Arrington, 73 F.3d 144, 147 (7th Cir.1996)). We have never, however, defined precisely what “good faith” means in this context. We now hold that to demonstrate “good faith,” a defendant need only show what the statutory language directs: that by the time of sentencing, he has “truthfully provided to the Government all information and evidence [he] has concerning the offense or offenses.” § 3553(f)(5). In this case, the district court construed good faith too broadly in determining that Mejia-Pimental was ineligible for relief. Because the court thus erred in its application of the safety valve and then sentenced…