De Jesus v. United States

Whether, when a court erroneously holds that it lacks jurisdiction to decide a matter, a cursory statement that the court would deny relief on the merits if it had jurisdiction would qualify as an alternative holding, as determined by the 3rd, 4th, and 11th Circuits, or whether such a statement is instead merely dicta of no binding effect, as determined by the 5th, 6th, 7th, 9th, and 10th Circuits.