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United States v. Lorenzo Taylor, Jr. - Appeal of Compassionate Release Denial

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Filed March 24th, 2026
Detected March 26th, 2026
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Summary

The Eleventh Circuit Court of Appeals affirmed the district court's denial of Lorenzo Taylor, Jr.'s motion for compassionate release. The court found Taylor's notice of appeal to be untimely, despite a prior remand for consideration of Rule 4(b)(4) relief.

What changed

The Eleventh Circuit Court of Appeals has issued a non-precedential opinion in the case of United States v. Lorenzo Taylor, Jr., addressing his appeal from the denial of his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The court determined that Taylor's notice of appeal was untimely, referencing the 14-day time limit under Federal Rule of Appellate Procedure 4(b)(1)(A) and prior Eleventh Circuit precedent. The court noted that while a prior remand had occurred to consider Rule 4(b)(4) relief, the district court ultimately denied that motion, rendering the current appeal untimely.

This ruling means that Lorenzo Taylor, Jr. will not be granted compassionate release based on this appeal. The decision reinforces the importance of adhering to strict appellate filing deadlines, even in cases involving pro se litigants and motions for sentence reduction. Compliance officers in legal departments should note that appeals of compassionate release denials are subject to standard appellate timelines, and failure to meet these deadlines can result in dismissal, as demonstrated in this case.

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March 24, 2026 Get Citation Alerts Download PDF Add Note

United States v. Lorenzo Taylor, Jr.

Court of Appeals for the Eleventh Circuit

Combined Opinion

USCA11 Case: 24-11628 Document: 21-1 Date Filed: 03/24/2026 Page: 1 of 2

NOT FOR PUBLICATION

In the
United States Court of Appeals
For the Eleventh Circuit


No. 24-11628
Non-Argument Calendar


UNITED STATES OF AMERICA,
Plaintiff-Appellee,
versus

LORENZO TAYLOR, JR.,
a.k.a. Benzo,
Defendant-Appellant.


Appeal from the United States District Court
for the Southern District of Alabama
D.C. Docket No. 1:12-cr-00056-WS-C-1


Before JORDAN, ROSENBAUM, and NEWSOM, Circuit Judges.
PER CURIAM:
USCA11 Case: 24-11628 Document: 21-1 Date Filed: 03/24/2026 Page: 2 of 2

2 Opinion of the Court 24-11628

Lorenzo Taylor, Jr., proceeding pro se, appeals from the dis-
trict court’s April 9, 2024, order denying his motion for compas-
sionate release under 18 U.S.C. § 3582 (c)(1)(A). As we have already
explained, his notice of appeal is deemed filed on May 17, 2024, un-
der the prison mailbox rule. See Fed. R. App. P. 4(c)(1) (describing
the rule); Houston v. Lack, 487 U.S. 266, 276 (1988) (holding that,
under the rule, a notice of appeal filed by a pro se prisoner through
a prison’s mail system is deemed filed on the date that he delivered
it to prison authorities for mailing).
The government filed a motion to dismiss. As relevant, the
government argued that this appeal is untimely but suggested that
remand might be necessary to determine whether Taylor war-
ranted Rule 4(b)(4) relief. We issued an order construing the notice
of appeal as a Rule 4(b)(4) motion and remanding the case to the
district court to make such a determination. On remand, the dis-
trict court denied the construed Rule 4(b)(4) motion.
As a result, Taylor’s notice of appeal is untimely and, be-
cause the government has raised the issue, we must apply the
14-day time limit. See Fed. R. App. P. 4(b)(1)(A); United States v.
Lopez, 562 F.3d 1309, 1311-14 (11th Cir. 2009); see also United States
v. Fair, 326 F.3d 1317, 1318 (11th Cir. 2003) (explaining that motions
for sentence reduction are “criminal in nature”).
Accordingly, the government’s motion to dismiss is
GRANTED. This appeal is DISMISSED.

CFR references

18 U.S.C. § 3582

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
11th Circuit
Filed
March 24th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
No. 24-11628
Docket
24-11628

Who this affects

Applies to
Criminal defendants
Activity scope
Appeals Compassionate Release Motions
Geographic scope
United States US

Taxonomy

Primary area
Criminal Justice
Operational domain
Legal
Topics
Sentencing Appeals

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