Case Explained: Summary Calendar United States of America Plaintiff— v. Hamilton Douglas Lanza-Rios Defendant—

Court: United States Court of Appeals for the Fifth Circuit Filed: 2026-06-29 The Fifth Circuit granted the Government’s motion for summary affirmance and affirmed the judgment of the district court. The court held that Defendant Hamilton Douglas Lanza-Rios’s sole argument on appeal—that the sentencing enhancement under 8 U.S.C. § 1326(b) is unconstitutional—is foreclosed by the Supreme Court’s decision in *Almendarez-Torres v. United States*, 523 U.S. 224 (1998), as reaffirmed in *Erlinger v. United States*, 602 U.S. 821 (2024). The court noted that *Almendarez-Torres* remains a valid exception permitting judges to find only the fact of a prior conviction without a jury determination, and cited *United States v. Pervis* for this proposition within the Fifth Circuit. Consequently, the court denied the Government’s alternative motion for an extension of time and affirmed the conviction and sentence for illegal reentry under 8 U.S.C. § 1326(a) and (b). Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.