After serving about 10 years of his 20-year sentence for participating in a carjacking resulting in death, Víctor Miguel Duluc-Méndez moved for compassionate release to care for his ailing mother. Duluc’s motion was primarily based on his mother’s deteriorating health and his siblings’ inability to provide care. He also detailed extensive rehabilitation efforts during his decade in prison. The district court denied relief in a brief order, finding the reasons for Duluc’s request unconvincing and “commonplace,” and citing his criminal record as weighing “against release.” The court did not mention Duluc’s rehabilitation.
On appeal, the First Circuit vacated and remanded. Although rehabilitation on its own is insufficient to meet the “extraordinary and compelling” standard, the district court failed to address Duluc’s argument that rehabilitation, in combination with his family circumstances, warranted relief under either § 3582(c)(1)(A) or in the § 3553(a) analysis. Additionally, the panel noted that, while sentencing judges may rely on their prior familiarity with a case, Duluc’s rehabilitation efforts arose after sentencing and merited discussion. The panel remanded for further proceedings but declined to order release outright.
Appeal from District of Puerto Rico.
Opinion by Aframe, joined by Rikelman and Elliott.