United States v. Jose Garfias-Garcia

── United States v. Jose Garfias-Garcia ── Case No.: 25-13052 Court: Court of Appeals for the Eleventh Circuit Date: March 30, 2026 Category: NEW USCA11 Case: 25-13052 Document: 14-1 Date Filed: 03/30/2026 Page: 1 of 4 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-13052 Non-Argument Calendar ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus JOSE MISAEL GARFIAS-GARCIA, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Florida D.C. Docket No. 4:11-cr-00037-RH-CAS-1 ____________________ Before JILL PRYOR, BRANCH, and KIDD, Circuit Judges. PER CURIAM: Jose Garfias-Garcia, a federal prisoner proceeding pro se, ap- peals the district court’s denial of his latest request for a sentence reduction under 18 U.S.C. § 3582(c). Section 3582(c)(1)(A) allows a USCA11 Case: 25-13052 Document: 14-1 Date Filed: 03/30/2026 Page: 2 of 4 2 Opinion of the Court 25-13052 district court to reduce a term of imprisonment if: (1) the 18 U.S.C. § 3553(a) factors favor doing so; (2) there are “extraordinary and compelling reasons” for doing so; and (3) a reduction would not be inconsistent with U.S.S.G § 1B1.13’s policy statement. United States v. Tinker, 14 F.4th 1234, 1237 (11th Cir. 2021). Courts need not ad- dress these three conditions in a specific sequence, as the lack of even one forecloses a sentence reduction. Id. at 1237–38. If a court finds against the movant on any one of these requirements, it can- not grant relief and need not analyze the other conditions. Id. On appeal, Garfias-Garcia argues that he has demonstrated extraordinary and compelling reasons for his release because he has served over ten years of his unusually long sentence. He also argues that his rehabilitation efforts, including his completion of his GED and other educational courses, as well as the fact that he is deport- able upon his release from prison, warrant relief under § 3553(a). The government, in turn, moves this Court for summary affir- mance. Summary disposition is appropriate where, as relevant here, “the position of one of the parties is clearly right as a matter of law so that there can be no substantial question as to the outcome of the case, or where . . . the appeal is frivolous.” Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). We review de novo a defendant’s eligibility for a sentence reduction, but review for an abuse of discretion a court’s denial of an eligible defendant’s reduc- tion request. United States v. Giron, 15 F.4th 1343, 1345 (11th Cir. 2021). USCA11 Case: 25-13052 Document: 14-1 Date Filed: 03/30/2026 Page: 3 of 4 25-13052 Opinion of the Court 3 As background, Garfias-Garcia has previously attempted to raise his present arguments before the district court to no avail. He was initially sentenced to 360 months of imprisonment after a jury found him guilty of conspiracy to distribute and possess with the intent to distribute cocaine and marijuana in 2012. However, four years later, on Garfias-Garcia’s motion, the district court recalcu- lated his guideline range to 292–365 months based upon Amend-