Ortega-Rodriguez v. United States

Summary

The Court held that a federal appellate court may not dismiss a criminal appeal merely because the defendant fled before the appeal and was recaptured before the appellate court obtained jurisdiction, unless the flight materially interferes with the appellate process. The Eleventh Circuit’s dismissal of petitioner Ortega‑Rodriguez’s appeal under the Holmes rule was vacated and the case was remanded for further proceedings. The dissent argued that the majority’s rule is too narrow and would have upheld the Eleventh Circuit’s dismissal.