United States v. Gregory Sanford (7th Cir. January 2021)
Compassionate Release, Sentencing, Seventh Circuit
|The Seventh Circuit joined the Fifth, Sixth, and Third Circuits in holding that the exhaustion requirement under 3582(c)(1)(A) is a “mandatory claim-processing rule” that cannot be waived by a court. Therefore a defendant filing a motion for sentence reduction must first submit a request the warden, wait 30 days or exhaust their remedies, or the Government may waive the requirement.