Supreme Court Report

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Jonathan Rangel-Salazar v. United States

IFP petition · United States Court of Appeals for the Fifth Circuit, No. 25-10822 · judgment December 19, 2025


Certiorari denied · April 20, 2026

Question presented

The decision in Erlinger v. United States, 602 U.S. 821 (2024), shows that Almendarez-Torres v. United States, 523 U.S. 224 (1998), can no longer be reconciled with Apprendi v. New Jersey, 530 U.S. 466 (2000). Should Almendarez-Torres be overruled? LIST OF PARTIES Jonathan Rangel-Salazar, petitioner on review, was the Defendant-Appellant below. The United States of America, respondent on review, was Plaintiff-Appellee. No party is a corporation. RELATED PROCEEDINGS • United States v. Rangel-Salazar, No. 3:24-CR-00266, U.S. District Court for the Northern District of Texas. Judgment entered on July 7, 2025. • United States v. Rangel-Salazar, No. 25-10822, U.S. Court of Appeals for the Fifth Circuit. Judgment entered on December 19, 2025.

Counsel of record

For petitioner
Christy Posnett Martin
Federal Public Defender-Northern District of Texas

For respondent
D. John Sauer
Solicitor General

Case

Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, April 20, 2026 · Certiorari denied

Proceedings

  1. Apr 20 2026
    Petition DENIED.
  2. Apr 02 2026
    DISTRIBUTED for Conference of 4/17/2026.
  3. Mar 25 2026
    Waiver of right of respondent United States to respond filed.
  4. Mar 10 2026
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due April 13, 2026)