United States v. Joe Nathan Pyatt, Jr.

Court of Appeals for the Eleventh Circuit·Decided March 9, 2026·No. 25-11079·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 25-11079

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus

JOE NATHAN PYATT, JR., Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:22-cr-20138-RKA-1

Before JORDAN, NEWSOM, and KIDD, Circuit Judges. PER CURIAM:

Joe Pyatt, Jr. appeals from the district court’s March 17, 2025 paperless order denying his motion to dismiss the indictment. He

2 Opinion of the Court 25-11079

sought dismissal of the indictment on the ground that his continued involuntary hospitalization was unlawful. However, the district court’s paperless order is not final, because all counts in the indictment remain pending, i.e., Pyatt has not been convicted or sentenced. See Flanagan v. United States, 465 U.S. 259, 263 (1984) (providing that the rule of finality “prohibits appellate review until conviction and imposition of sentence”). Moreover, the court’s paperless order is not immediately appealable under the collateral order doctrine. See United States v. Shalhoub, 855 F.3d 1255, 1260 (11th Cir. 2017) (describing the collateral order doctrine and recognizing a limited number of orders that implicate the doctrine in a criminal case).

Accordingly, this appeal is DISMISSED, sua sponte, for lack of jurisdiction. No petition for rehearing may be filed unless it complies with the timing and other requirements of 11th Cir. R. 40-3 and all other applicable rules.

Free access — add to your briefcase to read the full text and ask questions with AI

United States v. Joe Nathan Pyatt, Jr., (11th Cir. 2026).

United States v. Joe Nathan Pyatt, Jr. (United States v. Joe Nathan Pyatt, Jr.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Flanagan v. United States
465 U.S. 259 (Supreme Court, 1984)
United States v. Khalid A. Shalhoub
855 F.3d 1255 (Eleventh Circuit, 2017)