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.
The district court denied Jackson’s motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A) 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 Court’s Holding
The Fifth Circuit dismissed Jackson’s appeal from the compassionate-release ruling as untimely. Because the motion was a step in his criminal case, Federal Rule of Appellate Procedure 4(b) required a notice of appeal within 14 days. Jackson filed after both that deadline and the additional 30-day period during which the district court could have extended the deadline for excusable neglect or good cause. Although Rule 4(b)’s deadline is not jurisdictional, the court held that it was mandatory and had to be enforced because the government invoked it.
The court treated Jackson’s reconsideration motion as arising under Federal Rule of Civil Procedure 60(b). It concluded that he failed to establish entitlement to relief under any provision of Rule 60(b) and therefore showed no abuse of discretion in the denial of reconsideration. The court affirmed that order.
Key Takeaways
- A compassionate-release motion is treated as part of the criminal case for purposes of the 14-day appellate deadline.
- Rule 4(b)’s criminal-appeal deadline is mandatory when the government properly raises untimeliness, even though the deadline is not jurisdictional.
- A motion for reconsideration does not succeed without grounds supporting relief under Rule 60(b), and its denial is reviewed for abuse of discretion.
Why It Matters
The decision underscores that incarcerated defendants seeking review of compassionate-release rulings must act within the criminal appellate timetable. Missing both the 14-day filing period and the window for a possible extension can foreclose appellate review of the underlying ruling when the government objects.
It also shows that seeking reconsideration does not provide an automatic route around an expired appeal deadline. A defendant must independently satisfy Rule 60(b)’s requirements to obtain relief from the reconsideration ruling.