Manzo-Pulido
United States v. Manzo-Pulido
Opinion
Lead Opinion
MEMORANDUM **
Gerardo Manzo-Pulido appeals both his conviction pursuant to an unconditional guilty plea and his sentence. We affirm. Because the parties are familiar with the factual and procedural history, we will not recount it here.
Manzo-Pulido argues that the government violated his due process rights by failing to have a “qualified Spanish speaker” or “competent interpreter” translate his initial interview with law enforcement agents. “[I]t is well-settled that an unconditional guilty plea constitutes a waiver of the right to appeal all non-jurisdictional antecedent rulings and cures all antecedent constitutional defects.” United States v. Lopez-Armenta, 400 F.3d 1173, 1175 (9th Cir.2005). As ManzoPulido’s due process claim challenges an alleged deprivation of a constitutional right that occurred prior to the entry of his unconditional guilty plea, he has waived his right to appeal this issue.
Second, Manzo-Pulido appeals the district court’s decision to increase his offense level by two points for the “possession of a firearm” under U.S. Sentencing Guidelines Manual (“USSG”) § 2Dl.l(b)(l), when Manzo-Pulido admitted only to possessing an unloaded BB gun. However, §…