U.S. v. Skaggs

Dist. Ct. lacked jurisdiction to amend final judgment on instant criminal matter, even though Dist. Ct., as part of defendant’s original sentence, included broadly worded forfeiture order in final judgment. Record showed that Dist. Ct. entered in 2020 instant final judgment, and in 2022 granted government’s motion seeking entry of preliminary order of forfeiture that itemized specific property involved in forfeiture. Federal Rule of Criminal Procedure 35(a) allows only 14-day period after entry of final judgment to correct sentence, including orders of forfeiture, and instant motion, which served to impose different “punishment” on defendant than forfeiture order in final judgment, was made outside instant 14-day time frame. Accordingly, Ct. of Appeals vacated instant order seeking preliminary order of forfeiture and reinstated final judgment entered in 2020.