United States v. Jean Henry

── United States v. Jean Henry ── Court: Court of Appeals for the Eleventh Circuit Date: June 05, 2026 Category: NEW USCA11 Case: 25-13051 Document: 24-1 Date Filed: 06/05/2026 Page: 1 of 6 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-13051 Non-Argument Calendar ____________________ UNITED STATES OF AMERICA, Plaintiff-Appellee, versus JEAN HENRY, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:99-cr-00003-WPD-17 ____________________ Before JILL PRYOR, NEWSOM, and BRANCH, Circuit Judges. PER CURIAM: Jean Henry, proceeding pro se, appeals the denial of his mo- tion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The government moved for summary affirmance in response. It USCA11 Case: 25-13051 Document: 24-1 Date Filed: 06/05/2026 Page: 2 of 6 2 Opinion of the Court 25-13051 maintains that it is clearly right as a matter of law that the district court properly denied Henry’s motion. In support, it argues that (1) the district court did not abuse its discretion in balancing the § 3553(a) factors and concluding that they did not favor relief, (2) Henry did not show error in the district court’s rejection of his dan- ger to the community argument, and (3) Henry failed to establish extraordinary and compelling reasons for a reduction. The govern- ment also argues that we need only agree with any one of these three arguments to hold that the district court’s denial of § 3582(c)(1)(A) relief was proper. Summary disposition is appropriate either where time is of the essence, such as “situations where important public policy is- sues are involved or those where rights delayed are rights denied,” or where “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, as is more frequently the case, the appeal is frivolous.” Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1161–62 (5th Cir. 1969). We hold pro se pleadings to a “less strin- gent” standard than those drafted by licensed attorneys and “liber- ally” construe them. Tannenbaum v. United States, 148 F.3d 1262, 1263 (11th Cir. 1998). We review whether a defendant is eligible for a sentence re- duction under 18 U.S.C. § 3582(c)(1)(A) de novo. United States v. Gi- ron, 15 F.4th 1343, 1345 (11th Cir. 2021). Once we know the defend- ant is eligible, we then review the district court’s denial of the peti- tioner’s § 3582(c)(1)(A) motion for abuse of discretion. Id. Abuse USCA11 Case: 25-13051 Document: 24-1 Date Filed: 06/05/2026 Page: 3 of 6 25-13051 Opinion of the Court 3 of discretion occurs if the district court applies an incorrect legal standard, follows improper decision-making procedures, makes clearly erroneous factual findings, or commits a clear error of judg- ment. United States v. Harris, 989 F.3d 908, 911–12 (11th Cir. 2021). And though district courts must explain their decisions “adequately enough to allow for meaningful appellate review,” district courts generally have “a ‘range of choice’” in sentencing decisions. See Gir