Jones v. United States

District of Columbia Court of Appeals·Decided July 16, 2026·No. 24-CO-0217·Published

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 24-CO-0217

WONELL A. JONES, JR., APPELLANT,

V.

UNITED STATES, APPELLEE.

Appeal from the Superior Court of the District of Columbia (2022-CF1-006394)

(Maribeth Raffinan, Judge)

(Submitted January 6, 2026 Decided June 10, 2026 ∗)

Steven R. Kiersh for appellant.

Matthew M. Graves, United States Attorney at the time the brief was filed, with whom Chrisellen R. Kolb, Nicholas P. Coleman, Dana Joseph, and Mark Hobel, Assistant United States Attorneys, were on the brief, for appellee.

Before BECKWITH, MCLEESE, and DEAHL, Associate Judges.

∗ The decision in this case was originally issued as an unpublished Memorandum Opinion and Judgment. It is now being published upon the grant of appellee’s unopposed motion to publish. 2

DEAHL, Associate Judge: Wonell Jones, Jr. was arrested and charged with

first-degree murder. He spent more than a year in pretrial detention without being

indicted and eventually requested his “immediate release” on the grounds that the

prosecution had “abandoned” their case by failing to indict him within the nine

months contemplated by D.C. Code § 23-102. That provision instructs that if a

person has been detained on a criminal charge, “and within nine months thereafter

the grand jury shall not have taken action on the case, . . . the prosecution of such

charge shall be deemed to have been abandoned and the accused shall be set free.”

D.C. Code § 23-102. The trial court denied Jones’s release request, reasoning that

defense counsel had agreed to extend that statutory time period, thereby tolling the

nine-month indictment clock, and that agreement was binding on Jones. Jones

appealed that ruling.

Critically, after Jones filed his appeal, a grand jury indicted him for first-

degree murder. Apparently in light of that development, Jones now asks that we

dismiss the indictment against him and order he be released from detention, albeit

without prejudice—Jones acknowledges that a grand jury could subsequently re-

indict him and he could be detained under that indictment. The government counters

that even if Jones were correct that he was detained without indictment beyond the

nine-month window permitted by § 23-102, that would not be any ground to dismiss

the indictment that a grand jury ultimately returned against him: “[R]elease from 3

detention . . . and not dismissal is the remedy provided in § 23-102.” Price v. United

States, 476 A.2d 644, 647 (D.C. 1984) (emphasis added); id. at 648 (“[S]ome

defendants granted relief under § 23-102 will ultimately be indicted and prosecuted

. . . on the original charges which caused them to be detained.”). Furthermore, the

government argues that Jones also “would not be entitled to immediate release

because an indictment has since been returned,” a point that Jones does not seem to

dispute if we do not dismiss that indictment as he requests. We agree with the

government that Jones is not entitled to any of the relief he seeks and thus affirm the

trial court’s order.

Before explaining why we agree with the government that Jones cannot be

afforded any of the relief he seeks, we first address two preliminary issues regarding

our jurisdiction to hear this appeal and the appeal’s potential mootness. Neither party

raised these issues of their own accord, but “courts are obliged to satisfy themselves

that they have jurisdiction, even if no party has cast any doubt on the matter and

even if the parties affirmatively agree that the court has jurisdiction.” OverDrive,

Inc. v. Open eBook Forum, 288 A.3d 305, 312 (D.C. 2023). We conclude that we

have jurisdiction over this appeal and that it is not moot.

On the first point, subject to a host of exceptions, our jurisdiction is typically

limited to reviewing “final orders and judgments” that dispose of the entirety of the 4

dispute before the trial court. D.C. Code § 11-721(a)(1); but see id. at § 11-721(a)(2)

(listing several categories of appealable interlocutory orders); Cohen v. Beneficial

Indus. Loan Corp., 337 U.S. 541, 546-47 (1949) (discussing the “collateral order

doctrine” permitting the immediate appeal of certain interlocutory orders). The

denial of pretrial release does not dispose of the entire criminal case—there is no

final adjudication of guilty/not guilty, or any sentence imposed—and so Jones is

appealing from a nonfinal order and he requires some jurisdictional hook to do that.

He has such a jurisdictional hook, and it comes through our authority to hear

interlocutory appeals from pretrial detention orders. We generally have the authority

to immediately review both initial detention orders and orders declining to

reconsider or revise an order detaining an individual. See D.C. Code § 23-1324(b)

(“In any case in which a person . . . is ordered detained or an order for his detention

has been permitted to stand . . . an appeal may be taken.”); see also Blackson v.

United States, 897 A.2d 187, 192-93 (D.C. 2006) (denial of motion to reconsider

pretrial detention is an independently appealable order); In re Brown, 974 A.2d 884,

889 (D.C. 2009) (“[A]n order denying bail in a criminal case is [immediately]

appealable under the [collateral order] exception.”). While this case arises in the

somewhat distinctive posture of a pretrial detention challenge grounded in

§ 23-102’s timely indictment requirement, that is neither here nor there for

jurisdictional purposes where Jones was seeking his pretrial release. We conclude 5

that under either § 23-1324(b) or our collateral order precedents—and possibly

both—Jones can bring this immediate appeal from an order that denied his request

for pretrial release.

On the second point, regarding mootness, we conclude that this case is not

moot. We directed the parties to file supplemental pleadings on this issue after Jones

was indicted during the pendency of this appeal. The parties agree that this appeal is

not moot. “Mootness has been described,” somewhat imprecisely, “as ‘the doctrine

of standing set in a time frame: The requisite personal interest that must exist at the

commencement of the litigation (standing) must continue throughout its existence

(mootness).’” Arizonans for Off. Eng. v. Arizona, 520 U.S. 43, 68 n.22 (1997)

(quoting U.S. Parole Comm’n v.

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