March 11, 2026·25-40568·Per Curiam·By James Taylor
The United States Court of Appeals for the Fifth Circuit dismissed an appeal as moot because the defendant had been released from custody with no remaining supervised release term. The court granted the Federal Public Defender's motion to withdraw under Anders procedures.
The defendant, Leonardo Daniel Quintanilla-Rosales, appealed his sentence from the United States District Court for the Southern District of Texas. The Federal Public Defender filed a motion to withdraw and submitted a brief in accordance with Anders v. California and United States v. Flores. The defendant did not file a response but indicated he wished to appeal his sentence.
The court’s reasoning
The court determined that the defendant’s release from custody, with no additional term of supervised release, rendered any challenge to his sentence moot. The court cited Spencer v. Kemna to support this conclusion.
What it means going forward
Defendants who are released from custody without supervised release cannot pursue sentencing appeals, as such challenges are considered moot.
