United States v. Juan Aguiar Parada

• Court: Court of Appeals for the Eleventh Circuit
• Decided: April 7, 2026
• Docket: 24-12775
• Status: Unpublished

Opinion

USCA11 Case: 24-12775 Document: 29-1 Date Filed: 04/07/2026 Page: 1 of 4

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-12775 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

JUAN CARLOS AGUIAR PARADA, a.k.a. JC, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 0:21-cr-60213-RS-3 ____________________

Before BRANCH, ABUDU, and ANDERSON, Circuit Judges. PER CURIAM: Juan Carlos Aguiar Parada, a federal prisoner proceeding pro se, appeals the denial of his motion for compassionate release, USCA11 Case: 24-12775 Document: 29-1 Date Filed: 04/07/2026 Page: 2 of 4

2 Opinion of the Court 24-12775

pursuant to 18 U.S.C. § 3582(c)(1)(A). After careful review, and in light of intervening case law, we vacate and remand for further pro- ceedings. Aguiar Parada filed his motion for compassionate release in June 2024 and contended that he was eligible for four reasons: (1) his medical conditions; (2) sentencing disparities; (3) his rehabil- itation; and, most relevantly, (4) because he was the “only viable” caregiver for his ill brother. See U.S.S.G § 1B1.13(b)(3)(C)–(D) (ex- plaining that a defendant can show an “extraordinary and compel- ling reason[]” for compassionate release where “the defendant would be the only available caregiver” for an immediate family mem- ber (emphasis added)). After briefing, the district court denied Aguiar Parada’s motion in a paperless order. The court’s order states that Aguiar Parada “ha[d] not shown ‘extraordinary and compelling reasons’ warranting a sentence reduction.” 1 Aguiar Parada appealed. While Aguiar Parada’s appeal was pending, we issued an opinion in United States v. Robelo-Galo, which is relevant to this case. 166 F.4th 1311, 1313 (11th Cir. 2026). In Robelo-Galo, we answered “a question of first impression: what does it mean for an inmate to be the ‘only available caregiver’” under U.S.S.G. § 1B1.13(b)(3). Id. We rejected the government’s reading of § 1B1.13(b)(3)—that “any

1 Section 3582(c)(1) gives district courts authority to reduce a defendant’s sen-

tence when three conditions have been met. United States v. Tinker, 14 F.4th 1234, 1237 (11th Cir. 2021). Because the district court only ruled on the “ex- traordinary and compelling” condition, we do not address the others here. USCA11 Case: 24-12775 Document: 29-1 Date Filed: 04/07/2026 Page: 3 of 4

24-12775 Opinion of the Court 3

potential caregiver who is not himself ‘incapacitated’ is necessarily ‘available’”—and held that “an inmate must demonstrate that no other person is qualified and free to provide the needed care.” Id. at 1313, 1315 (emphasis in original). We explained that this requires a “fact-intensive inquiry” that “will turn on the unique facts of a particular case.” Id. at 1313, 1316. We provided a “non-exhaustive list” of five factors “that district courts should consider in determin- ing whether a potential caregiver is qualified and free.” Id. at 1316– 17. Finally, we held that a district court’s decision as to whether a defendant is the “only available caregiver” under U.S.S.G. § 1B1.13(b)(3) is primarily a factual inquiry that we review only for clear error. See id. at 1316. We often remand when intervening authority alters or clar- ifies the relevant legal standard. See, e.g., Powell v. Sch. Bd. of Volusia Cnty., 86 F.4th 881, 883 (11th Cir. 2023) (remanding in light of in- tervening Supreme Court authority); United States v. Republic of Honduras, 75 F.4th 1288, 1289 (11th Cir. 2023) (en banc) (same). This is because, even if the change in law does not establish clearly whether the district court erred, we are “a court of review, not a court of first view.” Callahan v. U.S. Dep’t of Health & Hum. Servs. ex rel. Azar, 939 F.3d 1251, 1266 (11th Cir. 2019). In light of Robelo-Galo, we vacate and remand for further pro- ceedings. We do so given our explanation of the meaning of “only available caregiver” under U.S.S.G § 1B1.13(b)(3), and our holding that the relevant analysis requires a “fact-intensive inquiry.” Robelo-Galo, 166 F.4th at 1316; see Guevara v. Lafise Corp., 127 F.4th USCA11 Case: 24-12775 Document: 29-1 Date Filed: 04/07/2026 Page: 4 of 4

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824, 832 (11th Cir. 2025) (remanding where district court “failed to provide a sufficient explanation to support its ruling”); United States v. Noriega, 676 F.3d 1252, 1263 (11th Cir. 2012) (explaining that we will not make factual findings in the first instance). We express no opinion on whether Aguiar Parada is, ulti- mately, eligible for a sentence reduction.2 However, for the rea- sons explained, we vacate and remand for further proceedings. VACATED AND REMANDED.

2 As noted above, the district court did not analyze whether either of the other

two prongs of the compassionate release inquiry were met, so we also express no view on whether those have been satisfied. Tinker, 14 F.4th at 1237 (“Be- cause all three conditions [within § 3582(c)(1)(A)] are necessary, the absence of even one would foreclose a sentence reduction.”).