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UNITED STATES v. MARULANDA TRUJILLO (2021)

United States Court of Appeals, Eleventh Circuit.2021-04-23No. No. 20-12218

Summary

Holding. The appeal is dismissed as moot because the court cannot grant meaningful relief following the appellant's death.

Fernando Vicente Marulanda Trujillo, a federal inmate serving a 210-month sentence for cocaine importation conspiracy, sought compassionate release under the First Step Act in April 2020, citing COVID-19 exposure and serious heart disease. The district court rejected his motion, citing public safety concerns regarding an international drug trafficker and noting that the Bureau of Prisons had implemented pandemic protections. Marulanda Trujillo appealed the denial.

During the pendency of the appeal, Marulanda Trujillo died on March 25, 2021, following a battle with COVID-19. His counsel notified the court and argued the case had become moot. The court agreed that because it could no longer provide meaningful relief to the deceased appellant—such as release or remand for reconsideration—the appeal presented no live controversy and therefore dismissed it as moot.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Mootness of appeal following death of appellant
  • Compassionate release under First Step Act based on COVID-19 and medical conditions
  • Public safety considerations in sentencing

Procedural posture

The defendant appealed the district court's denial of his motion for compassionate release, and the government moved for summary affirmance when the appellant died during the pendency of the appeal.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Fernando Vicente Marulanda Trujillo was a federal prisoner serving a sentence of 210 months for conspiring to import cocaine into the United States. In April 2020, when he was 68 years old, Marulanda Trujillo filed a motion for compassionate release under the First Step Act, see 18 U.S.C. § 3582(c)(1)(A)(i), based on the COVID-19 pandemic and his deteriorating physical health due to severe heart disease. The district court denied that motion, finding that it could not “justify from a public safety or public policy perspective releasing an international narcotics trafficker six years early,” and noting that the Federal Bureau of Prisons had taken measures in response to the pandemic. Marulanda Trujillo appealed, and the government moved for summary affirmance.

However, on March 26, 2021, while this appeal was pending, Marulanda Trujillos counsel filed a notice with this Court stating that Marulanda Trujillo “passed away on March 25, 2021, after a long battle with COVID-19.” Counsel suggests that this proceeding is now moot. We are sorry to hear of Trujillos death. But we must agree that his case is now moot.

“A case on appeal becomes moot, and ceases to be a case or controversy, when it no longer presents a live controversy with respect to which the court can give meaningful relief.” United States v. Al-Arian, 514 F.3d 1184, 1189 (11th Cir. 2008) (quotation marks omitted).

This appeal is now moot because we cannot give meaningful relief to Marulanda Trujillo—such as release from prison or remand for additional consideration of his request for compassionate release—following his death. See id. We therefore dismiss the appeal as moot.

DISMISSED.

PER CURIAM: