United States v. Naranjo

In United States v. Naranjo, —- F.4th —-, No. 22-50938 (5th Cir. May 21, 2024), the Fifth Circuit affirmed the district court’s denials of the defendant’s motions for a sentence reduction under Section 404 of the First Step Act of 2018.

Statutory Text: Section 404(c) dictates that no court “shall entertain a motion made under this section to reduce a sentence if the sentence was previously imposed or previously reduced” under the Fair Sentencing Act of 2010 or “if a previous motion made under this section to reduce the sentence was, after the date of enactment of this Act, denied after a complete review of the motion on the merits.”

Holding: Section 404(c) of the First Step Act is a claim-processing rule, rather than a jurisdictional one.

A jurisdictional prescription limits “the circumstances in which Article III courts may exercise judicial power,” while a claim-processing rule merely requires parties to “‘take certain procedural steps at certain specified times.’” United States v. Franco, 973 F.3d 465, 467 (5th Cir. 2020) (quoting Henderson v. Shinseki, 562 U.S. 428, 435 (2011)).

A rule is only jurisdictional if Congress has clearly said as much. In Section 404(c) the First Step Act, Congress gave no such indication, so the provision is a claim-processing rule. Accord United States v. Hart, 983 F.3d 638 (3d Cir. 2020); United States v. Deruise, No. 22-12983, 2023 WL 3668929 (11th Cir. May 26, 2023).

Result: A claim-processing rule can still be mandatory even though it is not jurisdictional. If a party properly raises the rule, “a court must enforce the rule.” Fort Bend Cnty. v. Davis, 139 S. Ct. 1843, 1849 (2019). Here, the Government properly raised Section 404(c), so it must be enforced.

The district court had erroneously treated 404(c) as jurisdictional, but it reached the correct result by dismissing the defendant’s motion. That outcome was affirmed.