United States v. Leon Spikes, Sr.
CourtCourt of Appeals for the Eleventh Circuit
Date FiledNovember 3, 2026
Docket26-10132
StatusUnpublished
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Full Opinion
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NOT FOR PUBLICATION
In the
United States Court of Appeals
For the Eleventh Circuit
____________________
No. 26-10132
Non-Argument Calendar
____________________
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
versus
LEON BERNARD SPIKES, SR.,
Defendant-Appellant.
____________________
Appeal from the United States District Court
for the Middle District of Georgia
D.C. Docket No. 7:08-cr-00007-LAG-CHW-2
____________________
Before JILL PRYOR, BRANCH, and KIDD, Circuit Judges.
PER CURIAM:
Leon Bernard Spikes, Sr., appeals the district court’s denial
of his motion for compassionate release, filed pursuant to 18 U.S.C.
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2 Opinion of the Court 26-10132
§ 3582(c)(1)(A). After careful review, we agree with Spikes that va-
catur is warranted because the district court applied the incorrect
legal standard in denying the instant motion. In addition to com-
mitting this reversible error, the district court failed to sufficiently
explain its reasons for denying the requested relief, which deprives
our Court of the ability to meaningfully review the contested issues
on appeal. We therefore vacate the district court’s order and re-
mand for further proceedings.
I. BACKGROUND
In 2009, Spikes was convicted for armed bank robbery and
possessing a firearm during a crime of violence. He ultimately was
sentenced to 270 months of imprisonment. Spikes thereafter filed
multiple motions seeking compassionate release.
Proceeding pro se, Spikes filed his first motion in September
2022, which the district court denied. In its order, the court ex-
plained that the policy statements included in § 1B1.13 of the
United States Sentencing Guidelines had not been updated since
the First Step Act of 2018 allowed prisoners to move for compas-
sionate release. It found that Spikes’s motion did not fall under any
of the categories described in § 1B1.13, and there was no record
that he had exhausted his administrative remedies with the Bureau
of Prisons (“BOP”). Spikes refiled his motion two months later,
which the district court denied for the same reasons provided in its
previous order.
Several months later, Spikes filed his third motion, arguing
that multiple “extraordinary and compelling reasons” warranted a
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26-10132 Opinion of the Court 3
reduction of his sentence, including (1) the Sentencing Commis-
sion’s then-proposed amendments regarding “unusually long sen-
tences”; (2) his rehabilitation during his incarceration; (3) the
BOP’s miscalculation of his time in jail for credit purposes; (4) the
obsolete nature of his career-offender status; and (5) his family cir-
cumstances. The district court again denied relief, reiterating its
previous reasoning.
In February 2024, Spikes filed his fourth pro se compassion-
ate release motion—the filing that gives rise to the instant appeal.
In this motion, Spikes reiterated the same “extraordinary and com-
pelling reasons” raised in his previous motion. He also provided a
letter to the district court describing the rehabilitation efforts he
had made during his incarceration and requesting that the remain-
der of his sentence be reduced to account for time-served credit he
should have received. Spikes was also permitted to file a supple-
mental brief through counsel. In that supplement, counsel noted
that the Sentencing Commission had amended § 1B1.13 since the
denial of Spikes’s last motion.
Following the government’s response, the district court de-
nied Spikes’s motion in an order nearly identical to those that it
issued previously. This appeal followed.
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4 Opinion of the Court 26-10132
II. STANDARD OF REVIEW
We review de novo a defendant’s eligibility for relief under
§ 3582(c)(1)(A). United States v. Giron, 15 F.4th 1343, 1345 (11th Cir.
2021). “After eligibility is established, we review a district court’s
denial of a prisoner’s § 3582(c)(1)(A) motion for an abuse of discre-
tion.” Id.
III. DISCUSSION
A district court has no inherent authority to modify a de-
fendant’s sentence and may do so “only when authorized by a stat-
ute or rule.” United States v. Puentes, 803 F.3d 597, 606 (11th Cir.
2015). A district court may reduce a term of imprisonment under
§ 3582(c)(1)(A) if “(1) extraordinary and compelling reasons war-
rant such a reduction, (2) such a reduction is consistent with appli-
cable policy statements issued by the Sentencing Commission, and
(3) [the 18 U.S.C.] § 3553(a) sentencing factors weigh in favor of a
reduction.” Giron, 15 F.4th at 1346 (citation modified). The district
court may consider these factors in any order, and the absence of
any of the three forecloses a sentence reduction. See United States v.
Tinker, 14 F.4th 1234, 1237–38 (11th Cir. 2021).
As an initial matter, the parties contest the appropriate
standard of review. We understand this disagreement, as it is un-
clear whether the district court found Spikes ineligible for compas-
sionate release or determined that, despite his eligibility, the rele-
vant factors weighed against reducing Spikes’s sentence. In the in-
stant order, the district court initially stated that Spikes’s “motion
does not fall within any of the categories enumerated at [U.S.S.G.]
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26-10132 Opinion of the Court 5
§ 1B1.13.” However, the court went on to state that it was denying
Spikes’s requested relief “[a]fter careful and complete review” of
the instant motion, “as well as the previous motions he ha[d] sub-
mitted to the [c]ourt; the applicable factors set forth in 18 U.S.C.
§ 3553(a) and the applicable policy statements issued by the Sen-
tencing Commission to the extent they are relevant to whether a
reduction is warranted (and, if so, the amount of the reduction).”
Based on these statements, we will assume for the purposes of our
analysis that the district court found Spikes eligible for compassion-
ate release but denied his motion as a matter of discretion. We will
therefore apply abuse-of-discretion review to this appeal. See Giron,
15 F.4th at 1345.
We are mindful that “deference is the hallmark of abuse-of-
discretion review.” United States v. Ware, 69 F.4th 830, 845 (11th Cir.
2023) (citation modified). However, this review “is not simply a
rubber stamp.” United States v. Cook, 998 F.3d 1180, 1183 (11th Cir.
2021) (citation modified). We have recognized that a district court
abuses its discretion if it applies an incorrect legal standard, follows
improper procedures in making its determination, makes clearly
erroneous factual findings, or commits a clear error of judgment.
See Giron, 15 F.4th at 1345; United States v. Harris, 989 F.3d 908,
911–12 (11th Cir. 2021). We find that Spikes’s case presents such
circumstances.
First, the district court applied the incorrect legal standard in
conducting its analysis—a prior version of U.S.S.G. § 1B1.13. In its
order, the court stated that “the policy statements [in § 1B1.13]
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6 Opinion of the Court 26-10132
were not amended after” the First Step Act “allow[ed] prisoners to
file direct motions for compassionate release.” However, as
Spikes’s counsel noted, the Sentencing Commission amended
§ 1B1.13 to reflect the First Step Act’s change to § 3582(c)(1)(A) in
2023. See U.S. Sentencing Commission, Adopted Amendments (Ef-
fective November 1, 2023), Amendment 814. Rather than recogniz-
ing this substantive change, the district court denied Spikes’s latest
motion with outdated language duplicative of that used in its or-
ders denying the motions filed prior to Amendment 814 taking ef-
fect.
Further, the district court was required to “explain its sen-
tencing decisions adequately enough to allow for meaningful ap-
pellate review.” Giron, 15 F.4th at 1345 (citation modified). That did
not occur in this case. Despite receiving full briefing from the par-
ties, nothing in the district court’s order suggests that it actually
assessed Spikes’s claims or the government’s counterarguments.
Rather, it appears that the court conducted a cursory application of
the incorrect version of § 1B1.13. From the order, we cannot deter-
mine which factors the district court relied upon in denying relief.
See Cook, 998 F.3d at 1185 (stating that, “[a]t minimum, [this Court]
must be able to understand from the record how the district court
arrived at its conclusion, including what factors it relied upon”).
These errors require vacatur of the district court’s order. See
id. at 1183, 1185–86. On remand, the district court should apply the
correct version of § 1B1.13 and provide express reasoning for deny-
ing Spikes’s motion for compassionate release.
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26-10132 Opinion of the Court 7
IV. CONCLUSION
We VACATE the district court’s order denying Spikes’s
compassionate release motion and REMAND this case for further
proceedings consistent with this opinion.