Court Opinion: 10th Circuit Court of Appeals Opinion for July 20

The 10th Circuit Court of Appeals

Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.

United States v. Fields

Leonidas Fields appealed an order by the Western District of Oklahoma dismissing his motion for compassionate release for lack of jurisdiction. 

In 1975, Leonidas Fields was in prison serving a sentence for armed bank robbery. While serving this sentence, a jury convicted Fields of first-degree murder of a correctional officer engaged in his official duties. As a result, Fields was sentenced to life in prison to run consecutively with his current sentence.

On Jan. 29, 2021, Fields filed a motion for compassionate release in the Western District of Oklahoma. The district court dismissed the motion for lack of jurisdiction. The district court reasoned Fields was sentenced before the effective date of the sentencing guidelines. The compassionate release statute didn’t apply to him. Even if the statute did apply, the district court still found Fields failed to satisfy the three requirements of the statute.

Fields filed a second motion for compassionate release on March 25, 2022. The district court dismissed that motion under the same jurisdictional grounds as Fields’s first motion and because Fields failed to show an extraordinary and compelling reason for granting a sentence reduction.

Fields appealed the dismissal of his second motion.

On appeal, Fields argued his conviction was due to a conspiracy connected to his religious practice as a member of the nation of Islam. Because he proceeded pro se, an Oklahoma panel of the 10th Circuit Court of Appeals analyzed his filings but didn’t act as his advocate. 

While a pro se litigant is entitled to a liberal construction of his filings, pro se status doesn’t mean a litigant is excused from complying with the fundamental requirements of appellate procedure, the opinion noted, citing the 10th Circuit Court of Appeals decisions in Garrett v. Selby Connor Maddux & Janer and Yang v. Archuletta. To adequately brief an issue under Federal Rule of Appellate Procedure 28, an appellant must include “more than a generalized assertion of error,” the opinion noted, citing the 7th Circuit Court of Appeals decision in Anderson v. Hardman. Specifically, an appellant’s opening brief must identify the “appellant’s contentions and the reasons for them.” As such, “the omission of an issue in an opening brief generally forfeits appellate consideration of the issue,” the opinion noted, citing the 10th Circuit Court of Appeals decisions in Bronson v. Swensen and United States v. Billingsley. Even for pro se filings, the appeals court explained that, in light of Garrett, issues and challenges to judgments of a district court are deemed forfeited or waived if the issues are not adequately briefed.

According to the opinion, Fields’s opening brief didn’t raise a claim of error by the district court. The district court’s rationale was the statute was inapplicable to Fields as he committed his offense prior to the date it became effective. As a result, the district court lacked jurisdiction to consider the motion. Fields didn’t address the applicability of the statute to his offense in his opening brief nor did he mention the jurisdictional issue identified by the district court, the opinion added. While Fields did ask for his release in the briefing, he didn’t do so by challenging the district court’s ruling on his motion for compassionate release. Instead, Fields challenged the basis for his first-degree murder conviction. However, this wasn’t an issue the district court considered or ruled on for the purposes of Fields’s appeal.

The 10th Circuit found Fields inadequately briefed the issues by failing to challenge the district court’s decision to deny his motion for compassionate release in his opening brief.

The 10th Circuit affirmed the district court’s dismissal of Fields’s motion for compassionate release.

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