Case Explained: UNITED STATES OF AMERICA v. JOSEPH R. BEILHARZ

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-03 The fourth-circuit vacated the district court’s order partially granting the defendant’s motion for reconsideration and remanded the case for further proceedings. The court held that the district court lacked jurisdiction to grant the motion because the defendant had already filed a notice of appeal, which divested the district court of authority to alter the status of the case pending appellate review. Under Federal Rule of Criminal Procedure 37(a), a district court may defer considering, deny, or state that it would grant a reconsideration motion if remanded, but it may not actually grant such a motion while an appeal is pending. Consequently, the partial modification of the garnishment disposition order was deemed a nullity, leaving only the original March 4 order for review. On remand, the district court is directed to consider the defendant’s response in opposition and subsequent filings to determine whether a hearing is necessary to establish the proper garnishment amount. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.