Unreported / Non-Citable
Background
Ronnie Jackson is serving a 142-month federal prison sentence following convictions on four counts of interference with commerce by robbery and one count of brandishing a firearm during a crime of violence. He moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), but the district court denied the motion on December 5, 2025.
Jackson later sought reconsideration, which the district court also denied. He appealed both rulings, filing his notice of appeal no earlier than February 19, 2026. The government invoked the time limit imposed by Federal Rule of Appellate Procedure 4(b).
The Court’s Holding
The Fifth Circuit dismissed Jackson’s appeal from the compassionate-release ruling as untimely. Because a compassionate-release motion is a step in the criminal case, Jackson had 14 days—until December 19, 2025—to appeal. His notice also fell outside the additional 30-day period during which the district court could have granted an extension for excusable neglect or good cause. Although Rule 4(b)’s deadline is not jurisdictional, it is mandatory when the government invokes it.
The court separately affirmed the denial of reconsideration. Construing Jackson’s reconsideration motion as one arising under Federal Rule of Civil Procedure 60(b), the court concluded that he had not established a basis for relief under any provision of Rule 60(b) and therefore had not shown that the district court abused its discretion.
Key Takeaways
- An appeal from the denial of compassionate release is governed by the 14-day deadline for criminal appeals.
- When the government invokes Rule 4(b), the Fifth Circuit will enforce an untimely criminal-appeal deadline even though it is not jurisdictional.
- A motion to reconsider the denial of compassionate release may be construed under Rule 60(b), but the movant must establish a recognized ground for relief.
Why It Matters
The decision underscores that prisoners seeking review of compassionate-release rulings must act within the short deadline applicable to criminal appeals. Filing beyond both the 14-day appeal period and the district court’s 30-day extension window forecloses appellate review when the government raises untimeliness.
It also confirms that a reconsideration motion does not provide relief merely because the underlying compassionate-release request was unsuccessful; the movant must satisfy Rule 60(b)’s requirements and overcome deferential abuse-of-discretion review.