United States v. Edwin Pawlowski (3rd Cir. July 2020)

The Federal Docket

August 21, 2020

Compassionate Release/Standard of Review – A district court’s denial of a motion for compassionate release under 18 U.S.C. § 3582(c) is reviewed for an abuse of discretion.

Edwin Pawlowski was serving a fifteen-year sentence when he moved for compassionate release under 18 U.S.C. § 3582(c) due to COVID-19 and his medical ailments. He appealed the district court’s denial of his motion.

The Court disagreed, holding that the district court “reasonably concluded that several of the § 3553(a) factors . . . counsel[ed] against compassionate release.”

The Court also held that the standard of review of “a district court’s determination that the § 3553(a) factors do not weigh in favor of granting compassionate release” is an abuse of discretion standard. Therefore, “‘unless there is a definite and firm conviction that [the district court] committed a clear error of judgment in the conclusion it reached upon a weighing of the relevant factors,’” the district court’s decision will not be disturbed.

Appeal from the Eastern District of Pennsylvania

Opinion by Ambro, joined by Krause and Bibas

Click here to read the opinion.

Tom Church - Tom is a trial and appellate lawyer focusing on criminal defense and civil trials. Tom is the author of "The Federal Docket" and is a contributor to Mercer Law Review's Annual Survey in the areas of federal sentencing guidelines and criminal law. Tom graduated with honors from the University of Georgia Law School where he served as a research assistant to the faculty in the areas of constitutional law and civil rights litigation. Read Tom's reviews on AVVO. Follow Tom on Linkedin.

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