United States v. Tiffany Brown

U.S. Court of Appeals for the Eleventh Circuit

United States v. Tiffany Brown

Opinion

USCA11 Case: 25-11785 Document: 17-1 Date Filed: 09/03/2025 Page: 1 of 3

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11785 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

TIFFANY BROWN, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:22-cr-00359-TWT-JEM-1 ____________________

Before ROSENBAUM, GRANT, and BRASHER, Circuit Judges. PER CURIAM: Tiffany Brown, a criminal defendant who had been released from custody pending the resolution of her case, was sentenced to 144 months’ imprisonment and directed to report to a federal USCA11 Case: 25-11785 Document: 17-1 Date Filed: 09/03/2025 Page: 2 of 3

2 Opinion of the Court 25-11785

prison. She filed a pro se motion to delay the start of her prison term. The district court denied that motion on May 20, 2025, Brown filed a notice of appeal from that denial, and the district court then reconsidered and delayed Brown’s prison report date to June 20, 2025. Since then, Brown surrendered as directed, starting her term of imprisonment. In a jurisdictional question, we asked the parties to address whether the appeal is moot given the district court’s order that Brown report to prison on June 20, 2025. Both parties respond that Brown has begun her prison term and that the appeal is moot. We agree. Brown’s appeal from the district court’s May 20, 2025, order is moot because we can no longer give her the relief she was seek- ing now that she has reported to prison and begun her prison term. See Zinni v. ER Solutions, Inc., 692 F.3d 1162, 1166 (11th Cir. 2012) (“An issue is moot when it no longer presents a live controversy with respect to which the court can give meaningful relief.” (quo- tation marks omitted)); Brooks v. Ga. State Bd. of Elections, 59 F.3d 1114, 1118-19 (11th Cir. 1995) (explaining that a controversy can become moot “by reason of intervening events” (quotation marks omitted)). None of the “well-established” exceptions to the moot- ness doctrine apply. See Brooks, 59 F.3d at 1120-21 (discussing those exceptions). Accordingly, this appeal is DISMISSED for lack of jurisdic- tion. See Christian Coal. of Fla., Inc. v. United States, 662 F.3d 1182, 1189 (11th Cir. 2011) (explaining that our jurisdiction is limited to USCA11 Case: 25-11785 Document: 17-1 Date Filed: 09/03/2025 Page: 3 of 3

25-11785 Opinion of the Court 3

“cases” and “controversies,” which require, inter alia, that the issue or issues not be moot). This dismissal does not affect Brown’s ap- peal from her conviction and sentence, No. 25-11317, which is pending.

Reference

Status
Unpublished