United States v. Cano Bonilla - Plea Agreement Breach

11th Circuit Published Opinions (CourtListener)

Filed March 26th, 2026

Detected March 26th, 2026

Summary

The Eleventh Circuit Court of Appeals has jointly agreed with the parties to summarily reverse a lower court's decision in the case of United States v. Joseph Anthony Cano Bonilla. The appeal concerns an alleged breach of the plea agreement by the government, which the government now concedes.

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What changed

The Eleventh Circuit Court of Appeals is considering a joint motion for summary reversal in the case of United States v. Joseph Anthony Cano Bonilla (Docket No. 25-11039). The defendant pleaded guilty to distributing methamphetamine and was sentenced to 151 months. He appealed, arguing the government breached their plea agreement. The government has now agreed with the defendant's position, leading to this joint motion for summary reversal.

This case highlights the critical importance of adhering to the terms of plea agreements. Compliance officers should note that the government's concession suggests a potential procedural error or misstep in the original proceedings related to the plea agreement's promises. While this is a specific criminal case, it underscores the need for meticulous documentation and adherence to agreed-upon terms in all legal proceedings involving the government. The court's review of plea agreement breaches is de novo, meaning they will examine the agreement and its execution without deference to the lower court's findings.

What to do next

Review plea agreement terms for any potential ambiguities or areas of dispute.
Ensure all government promises within plea agreements are meticulously documented and adhered to.
Consult with legal counsel regarding any potential breaches of plea agreements to assess grounds for appeal or motion.

Source document (simplified)

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March 26, 2026 Get Citation Alerts Download PDF Add Note

United States v. Joseph Anthony Cano Bonilla

Court of Appeals for the Eleventh Circuit

Citations: None known
Docket Number: 25-11039
Precedential Status: Non-Precedential
Nature of Suit: NEW
Opinion
Authorities (3)
Cited By (0)
Summaries (0)
Similar Cases (17.8K)
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Combined Opinion

USCA11 Case: 25-11039 Document: 32-1 Date Filed: 03/26/2026 Page: 1 of 3

NOT FOR PUBLICATION

In the
United States Court of Appeals
For the Eleventh Circuit

No. 25-11039
Non-Argument Calendar

UNITED STATES OF AMERICA,
Plaintiﬀ-Appellee,
versus

JOSEPH ANTHONY CANO BONILLA,
a.k.a. Joesph Anthony Cano Bonilla,
Defendant-Appellant.

Appeal from the United States District Court
for the Southern District of Florida
D.C. Docket No. 1:24-cr-20449-KMM-1

Before ROSENBAUM, GRANT, and KIDD, Circuit Judges.
PER CURIAM:
Joseph Cano Bonilla pleaded guilty to distributing metham-
phetamine and was sentenced to 151 months of imprisonment. He
USCA11 Case: 25-11039 Document: 32-1 Date Filed: 03/26/2026 Page: 2 of 3

2 Opinion of the Court 25-11039

now appeals, arguing in relevant part that the government
breached the plea agreement. The government agrees with Cano
Bonilla’s position, and the parties jointly move our Court for sum-
mary reversal.
Summary disposition is appropriate where, as relevant here,
“the position of one of the parties is clearly right as a matter of law
so that there can be no substantial question as to the outcome of
the case.” Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th
Cir. 1969). “[W]e review de novo whether the government has
breached a plea agreement.” United States v. Malone, 51 F.4th 1311,
1318 (11th Cir. 2022). “[T]he government breaches a plea agree-
ment when it fails to perform the promises on which the plea was
based.” Id. at 1324 (citation omitted).
In this case, Cano Bonilla pleaded guilty to a single-count in-
dictment pursuant to a written plea agreement. As part of that
agreement, the government “agree[d] to remain silent on the pu-
rity of the methamphetamine,” and the parties predicted that Cano
Bonilla’s advisory sentencing guideline range would be 97 to 121
months of imprisonment. However, Cano Bonilla’s presentence in-
vestigation report (“PSI”) stated that he was responsible for a total
of 8,854 grams of a “pure substance” of “actual methampheta-
mine,” assessed a heightened offense level, and, coupled with Cano
Bonilla’s criminal history category of II, calculated a guideline
range of 151 to 188 months.
Cano Bonilla objected to these provisions of the PSI, but, at
sentencing, the district court noted that the probation officer had
USCA11 Case: 25-11039 Document: 32-1 Date Filed: 03/26/2026 Page: 3 of 3

25-11039 Opinion of the Court 3

reported that a chemical analysis report “revealed that the amount
of . . . pure substance . . . was 8,854 grams.” The government re-
sponded that “the guidelines [were] correct and the purity and the
lab report [were] correct,” so “instead of couching [its argument]
in terms of an objection to the guidelines,” it was more so request-
ing a downward variance. The district court ultimately adopted the
PSI’s guideline calculations and imposed a within-guideline sen-
tence of 151 months of imprisonment.
Here, the parties are clearly correct as a matter of law that
the government’s statement at sentencing breached its promise in
the plea agreement to remain silent as to the purity of the metham-
phetamine. Davis, 406 F.2d at 1162; Malone, 51 F.4th at 1324. Be-
cause Cano Bonilla preserved an objection to this breach at the sen-
tencing hearing, “automatic reversal is warranted.” United States v.
Hunter, 835 F.3d 1320, 1329 (11th Cir. 2016) (quoting Puckett v.
United States, 556 U.S. 129, 141 (2009)).
Accordingly, we GRANT the parties’ motion for summary
reversal. 1 Cano Bonilla’s judgment is VACATED, and this case is
REMANDED for resentencing in accordance with “the terms of
the [plea] agreement before a different judge.” Id.

1 The parties also request that we order the district court to strike the chemical

analysis report from the record and order the preparation of an amended PSI.
We DENY these requests WITHOUT PREJUDICE so the parties may seek
such relief directly from the district court on remand.