In United States v. Rufino Robelo-Galo (11th Cir. Feb. 17, 2026) (Brasher, Newson, Tjoflat), the Court held, on an issue of first impression, that a defendant seeking a reduction in sentence pursuant to 18 U.S.C. s. 3582(c)(1)(A)(i) & U.S.S.G. 1B1.13(b)(3)(C), as the “only available caregiver,” the defendant “must demonstrate that no other person is qualified and free to provide the needed care.” The Court also identified several factors for district courts to consider when making this “fact-intensive inquiry,” including: “whether legal barriers prevent the potential caregiver from providing care”; “physical or logistical barriers to caregiving”; “knowledge or capability-based barriers affect the caregiver’s qualifications”; “familial dynamics or relationship history that may bear on an alternative caregiver’s availability”; and “any economic, financial, or employment-related barriers that would impact a caregiver’s availability.”
The Court also affirmed the district court’s denial of Robelo-Galo’s motion, finding no “clear error” in the district court’s conclusion that Robelo-Galo was not “the only available caregiver” for his incapacitated grandfather, in Honduras, because another “close family member” was “also available”—even though that family member worked and lived 4 hours away, did not have a car, could not relocate to the grandfather because of his duties to his own children, and did not have space for the grandfather to live in his home.
Opinion here: https://media.ca11.uscourts.gov/opinions/pub/files/202412128.pdf