Jump To

Top Caption Combined Opinion

Support FLP

CourtListener is a project of Free
Law Project, a federally-recognized 501(c)(3) non-profit. Members help support our work and get special access to features.

Please become a member today.

Join Free.law Now

March 23, 2026 Get Citation Alerts Download PDF Add Note

United States v. Paul E. Senat

Court of Appeals for the Eleventh Circuit

• Citations: None known
• Docket Number: 25-11979
• Precedential Status: Non-Precedential

• Nature of Suit: NEW

• Opinion

• Authorities (4)

• Cited By (0)

• Summaries (0)

• Similar Cases (0)

• PDF

Combined Opinion

USCA11 Case: 25-11979 Document: 25-1 Date Filed: 03/23/2026 Page: 1 of 3

NOT FOR PUBLICATION

In the
United States Court of Appeals
For the Eleventh Circuit

No. 25-11979
Non-Argument Calendar

UNITED STATES OF AMERICA,
Plaintiff-Appellee,
versus

PAUL E. SENAT,
Defendant-Appellant.

Appeal from the United States District Court
for the Southern District of Florida
D.C. Docket No. 9:19-cr-80024-RAR-1

Before JORDAN, ROSENBAUM, and BRASHER, Circuit Judges.
PER CURIAM:
Paul E. Senat, proceeding pro se, appeals from the district
court’s July 31, 2023, order denying his motion for compassionate
release under 18 U.S.C. § 3582 (c)(1)(A). The government filed a
USCA11 Case: 25-11979 Document: 25-1 Date Filed: 03/23/2026 Page: 2 of 3

2 Opinion of the Court 25-11979

motion to dismiss Senat’s appeal as untimely. Senat did not re-
spond.
The deadline to file the notice of appeal was August 14, 2023.
See Fed. R. App. P. 4(b)(1)(A)(i) (providing that, in criminal cases, a
defendant must file a notice of appeal within 14 days after the entry
of the order or judgment being appealed); United States v. Fair, 326
F.3d 1317, 1318 (11th Cir. 2003) (explaining that sentence reduction
motions are “criminal in nature”). Under the prison mailbox rule,
the earliest that Senat’s notice could be deemed filed is May 25,
2025, the date that he signed it. 1 See Fed. R. App. P. 4(c)(1) (describ-
ing the prison mailbox rule); Houston v. Lack, 487 U.S. 266, 276
(1988) (explaining that, under the rule, a notice of appeal is deemed
filed on the date that the prisoner delivered it to prison authorities);
Jeffries v. United States, 748 F.3d 1310, 1314 (11th Cir. 2014) (explain-
ing that, absent evidence to the contrary, we assume that a prisoner
delivered his notice on the date that he signed it).
The notice is thus untimely to appeal from the July 31, 2023,
order. See Fed. R. App. P. 4(b)(1)(A)(i). The notice is also deemed
filed more than 30 days after the August 14 deadline, so Senat is not
eligible for an extension of time. See Fed. R. App. P. 4(b)(4) (provid-
ing that district courts can “extend the time to file a notice of appeal

1 It is unclear when Senat’s notice is deemed filed under the prison mailbox

rule because he dated it May 25, 2025, and the envelope in which it was mailed
is stamped as received by prison officials for mailing on June 2, 2025. The
eight-day difference, however, is not dispositive, as Senat’s notice is untimely
to appeal the district court’s July 31, 2023, order when deemed filed on either
date.
USCA11 Case: 25-11979 Document: 25-1 Date Filed: 03/23/2026 Page: 3 of 3

25-11979 Opinion of the Court 3

for a period not to exceed 30 days from the expiration of the time
otherwise prescribed by . . . Rule 4(b)”); United States v. Lopez, 562
F.3d 1309, 1314 (11th Cir. 2009).
Accordingly, because the government raised the issue of
timeliness, we must apply Rule 4(b)(1)(A)(i) and dismiss this appeal
as untimely. See Lopez, 562 F.3d at 1314. The motion to dismiss is
GRANTED, and this appeal is DISMISSED.