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United States v. Mahmood Khan Lodhi

Citations: 21 F.3d 606; 1994 WL 180921; 28 Fed. R. Serv. 3d 1543; 1994 U.S. App. LEXIS 10620Docket: 94-10364

Court: Court of Appeals for the Fifth Circuit; May 11, 1994; Federal Appellate Court

Narrative Opinion Summary

Mahmood Khan Lodhi's motion for release pending appeal has been denied by the Fifth Circuit Court of Appeals. The court clarified that the provisions of 18 U.S.C. § 3143 and Federal Rule of Appellate Procedure 9(b), which typically govern the release of a defendant pending sentence or appeal, do not apply to cases involving the revocation of supervised release. Release in such situations is only granted in the presence of exceptional circumstances. This includes demonstrating substantial claims with a high probability of success, serious health deterioration while incarcerated, or unusual delays in the appeal process, as established in United States v. Lacy. Lodhi failed to present any exceptional circumstances to justify his release, leading to the denial of both his motion for release and his request for a bond hearing.

Legal Issues Addressed

Exceptional Circumstances Requirement for Release

Application: The court requires exceptional circumstances for release in cases involving the revocation of supervised release, which Mahmood Khan Lodhi failed to demonstrate.

Reasoning: Release in such situations is only granted in the presence of exceptional circumstances. This includes demonstrating substantial claims with a high probability of success, serious health deterioration while incarcerated, or unusual delays in the appeal process, as established in United States v. Lacy. Lodhi failed to present any exceptional circumstances to justify his release.

Release Pending Appeal Under 18 U.S.C. § 3143

Application: The court determined that 18 U.S.C. § 3143 does not apply to cases involving the revocation of supervised release.

Reasoning: The court clarified that the provisions of 18 U.S.C. § 3143 and Federal Rule of Appellate Procedure 9(b), which typically govern the release of a defendant pending sentence or appeal, do not apply to cases involving the revocation of supervised release.