United States v. Joe Nathan Pyatt, Jr.

• Court: Court of Appeals for the Eleventh Circuit
• Decided: March 9, 2026
• Docket: 25-11079
• Status: Unpublished

Opinion

USCA11 Case: 25-11079 Document: 14-1 Date Filed: 03/09/2026 Page: 1 of 2

NOT FOR PUBLICATION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 USCA11 Case: 25-11079 Document: 14-1 Date Filed: 03/09/2026 Page: 2 of 2

2 Opinion of the Court 25-11079

sought dismissal of the indictment on the ground that his contin- ued involuntary hospitalization was unlawful. However, the dis- trict 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 pa- perless order is not immediately appealable under the collateral or- der 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.