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UNITED STATES v. RAMBO (2021)

United States Court of Appeals, Fifth Circuit.2021-08-19No. No. 20-11129

Summary

Holding. The court granted the government's motion to dismiss and dismissed Rambo's appeal as untimely because he failed to file his notice of appeal within the mandatory deadline and the district court lacked authority to extend that deadline under the circumstances.

Brandon Jamaal Rambo appealed the district court's denial of his motion for compassionate release under federal law. However, he filed his notice of appeal 98 days after the order was entered, well beyond the 30-day deadline required by the Federal Rules of Appellate Procedure. The government promptly objected to the timeliness of the appeal in its first substantive filing, thereby preserving the issue and preventing any waiver of the deadline requirement.

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

Key issues

  • Whether an appellate court may dismiss a criminal appeal filed after the mandatory notice deadline
  • Effect of government's timely objection to untimeliness on waiver of deadline requirement
  • Availability of deadline extensions for late notices of appeal

Procedural posture

Rambo appealed the district court's order denying his compassionate release motion, but the government moved to dismiss the appeal as untimely filed.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Brandon Jamaal Rambo has appealed the district courts order denying his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i). Rambos notice of appeal was filed 98 days after entry of the order appealed from and was therefore untimely. See Fed. R. App. P. 4(b)(1)(A)(i).

The Government has moved to dismiss the appeal because Rambo did not timely file his notice of appeal. Alternatively, it requests a 30-day extension to file a merits brief.

The Rule 4(b) time limit, although not jurisdictional, is mandatory. United States v. Hernandez-Gomez, 795 F.3d 510, 511 (5th Cir. 2015); see also Manrique v. United States, ––– U.S. ––––, 137 S. Ct. 1266, 1272, 197 L.Ed.2d 599 (2017) (holding that once the Government objected to the lack of a timely notice of appeal, the appellate courts “duty to dismiss the [criminal] appeal was mandatory” (internal quotation marks and citation omitted)). The Government has not waived the time limitation, as it contests the timeliness of Rambos notice of appeal in its first substantive filing. See Hernandez-Gomez, 795 F.3d at 511.

Rambo filed his notice of appeal after the expiration of the time for filing a timely appeal and beyond the time during which the district court could have granted him an extension upon a showing of either excusable neglect or good cause. See Fed. R. App. P. 4(b)(1)(A)(i), (b)(4); United States v. Alvarez, 210 F.3d 309, 310 (5th Cir. 2000). Accordingly, the Governments motion to dismiss is GRANTED, its alternative motion for an extension of time is DENIED as unnecessary, and the appeal is DISMISSED as untimely.

FOOTNOTES

FOOTNOTE

Per Curiam:*

FN* Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4.