United States v. James Abrams

── United States v. James Abrams ── Court: Court of Appeals for the Third Circuit Date: April 21, 2026 Category: General CLD-104 NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________ No. 25-3245 ___________ UNITED STATES OF AMERICA v. JAMES P. ABRAMS, Appellant ____________________________________ On Appeal from the United States District Court for the Middle District of Pennsylvania (M.D. Pa. No. 3:22-cr-00190-001) District Judge: Honorable Malachy E. Mannion ____________________________________ Submitted on Appellee’s Motion for Summary Action Pursuant to Third Circuit L.A.R. 27.4 and I.O.P. 10.6 April 2, 2026 Before: BIBAS, PHIPPS, and NYGAARD, Circuit Judges (Opinion filed: April 21, 2026) _________ OPINION * _________ PER CURIAM James P. Abrams appeals pro se from the District Court’s denial of his request for * This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. compassionate release and its subsequent denial of reconsideration. The Government has filed a motion for summary action. For the reasons that follow, we grant the Government’s motion and will summarily affirm the District Court’s judgment. Abrams is currently serving a term of imprisonment after a jury found him guilty of wire fraud, mail fraud, identity theft, money laundering, and related crimes. His 72- month sentence was below the Sentencing Guidelines range of 81-191 months, and he was ordered to pay about $1.2 million in restitution. United States v. Abrams, 165 F.4th 784, 792, 796 (3d Cir. 2026). His convictions stem from a scheme in which, “[t]o cozen funds for a clean energy startup, Abrams furnished prospective investors with forged documents and false information” and “then diverted investor funds for personal use and lied to investors to conceal his financial activities.” Id. at 792. We upheld his convictions and sentence on direct appeal. 1 Id. In 2025, less than a year into serving his sentence, Abrams filed a motion for compassionate release pursuant to 18 U.S.C. § 3582(c)(1)(A) in the District Court, seeking release to home confinement due to his medical conditions. The Government opposed the motion. The District Court concluded that Abrams had not demonstrated extraordinary and compelling reasons that warranted a sentence reduction, and that even if he had, upon considering the factors under 18 U.S.C. §3553(a), a sentence reduction was not appropriate given the circumstances of his convictions. Abrams sought reconsideration, and after that motion was denied, he appealed. 1 We also vacated a portion of an order and the amended judgment regarding attorneys’ fees and remanded for further proceedings solely as to that issue. Id. at 792-93. 2  We have jurisdiction under 28 U.S.C. § 1291. We review the District Court’s decisions for abuse of discretion. United States v. Pawlowski, 967 F.3d 327, 330 (3d Cir. 2020); United States v. Dupree, 617 F.3d 724, 732 (3d Cir. 2010). We may summarily affirm a district court’s decision if the appeal fails to present a substantial question. Murray v. Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011) (per curiam). We grant the Government’s motion for summary action. The compassionate- release provision states th