United States v. Vanessa Kaiser

USCA11 Case: 26-10843 Document: 14-1 Date Filed: 08/21/2026 Page: 1 of 4

NOT FOR PUBLICATION

In the

United States Court of Appeals

For the Eleventh Circuit

____________________ No. 26-10843 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA,

Plaintiff-Appellee, versus VANESSA VANLY KAISER,

Defendant-Appellant.

____________________

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:24-cr-80069-AMC-1 ____________________

Before JORDAN, ABUDU, and KIDD, Circuit Judges.

PER CURIAM:

Vanessa Vanley Kaiser, a federal prisoner proceeding pro se, appeals the district court’s denial of her motion for compassionate 2 Opinion of the Court 26-10843 release under 18 U.S.C. § 3582(c)(1)(A). 1 The government moves for summary affirmance. After careful review, we grant the gov- ernment’s motion and affirm.

Summary disposition is appropriate in several situations, in- cluding 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 . . . .” Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). 2 “We review de novo whether a defendant is eligible for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A).” United States v. Giron, 15 F.4th 1343, 1345 (11th Cir. 2021). “After eligibility is established, we review the district court’s denial of a prisoner’s § 3582(c)(1)(A) motion for an abuse of discre- tion.” Id. In applying these standards, we liberally construe the filings of pro se parties. United States v. Webb, 565 F.3d 789, 792 (11th Cir. 2009); Wright v. Newsome, 795 F.2d 964, 967 (11th Cir. 1986).

Section 3582(c)(1)(A) gives a district court authority to re- duce a defendant’s sentence where three conditions are present: “(1) the [18 U.S.C.] § 3553(a) sentencing factors favor doing so, (2) there are ‘extraordinary and compelling’ reasons for doing so, 26-10843 Opinion of the Court 3 and . . . , (3) doing so wouldn’t endanger any person or the com- munity within the meaning of [U.S.S.G.] § 1B1.13’s policy state- ment.” United States v. Tinker, 14 F.4th 1234, 1237 (11th Cir. 2021) (quoting 18 U.S.C. § 3582(c)(1)(A)); see also United States v. Bryant, 996 F.3d 1243, 1249–50 (11th Cir. 2021), superseded in part on other grounds by U.S.S.G. § 1B1.13 (2023). Because all three conditions are necessary, the absence of any one condition forecloses a sen- tence reduction. Tinker, 14 F.4th at 1237–38, 1240.

Here, the district court did not err in ruling on the second of these three conditions, see id. at 1237, and concluding that Kaiser had not shown an extraordinary and compelling reason for her re- lease. 3 Kaiser’s primary argument on this issue is that, at sentenc- ing, she did not receive safety-valve relief for which she was eligi- ble. However, she did receive the benefit of safety valve relief; her offense level was reduced by two and the presentence investigation report acknowledged that the district court was not bound by the otherwise-applicable statutory mandatory minimum. See 18 U.S.C. § 3553(f); U.S.S.G. §§ 2D1.1(b)(18), 5C1.2. For these 4 Opinion of the Court 26-10843 reasons, even though the district court ultimately sentenced Kaiser to a guidelines sentence of 73 months, which was higher than the 5-year mandatory minimum, Kaiser did in fact receive the benefit of the safety valve. On this record, therefore, any issue about the safety-valve does not constitute an extraordinary and compelling reason under U.S.S.G. § 1B1.13(b)(5), as the district court ex- plained. 4 In addition, Kaiser’s arguments about her rehabilitation cannot, alone, constitute an extraordinary and compelling reason for compassionate release. U.S.S.G. § 1B1.13(d) (“[R]ehabilitation of the defendant is not, by itself, an extraordinary and compelling reason for purposes of this policy statement.”).

For these reasons, the district court correctly concluded that Kaiser had not shown an extraordinary and compelling reason for her early release. Thus, “there can be no substantial question as to the outcome of the case,” so we GRANT the government’s motion for summary affirmance. Groendyke Transp., 406 F.2d at 1162.

AFFIRMED.