Full Opinion

USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 1 of 7 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 26-10132 Non-Argument Calendar ____________________ UNITED STATES OF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. USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 2 of 7 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 USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 3 of 7 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. USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 4 of 7 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.] USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 5 of 7 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] USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 6 of 7 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. USCA11 Case: 26-10132 Document: 20-1 Date Filed: 11/03/2026 Page: 7 of 7 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.