United States v. Jeffrey Charles Rodd (8th Cir. July 2020)

The Federal Docket

Sentencing/Compassionate Release

Jeffrey Rodd had various physical ailments and was projected to be released from federal custody in November 2020. Based on his numerous medical conditions,  Rodd filed a motion for compassionate release with the district court after the warden failed to respond to his request for a sentence reduction.

The district court considered Rodd’s claim that his medical conditions constituted “extraordinary and compelling reasons” warranting a sentence reduction under USSG 1B1.13, which sets forth four categories of criteria for release, including an inmate’s medical condition and family circumstances.

The court first considered whether Rodd’s claim fell under the pre-First Step Act definition of “extraordinary and compelling reasons,” which meant proving that his medical condition substantially diminished his ability to provide self-care while in custody. The district court recognized, however, that the definitions under 1B1.13 had not been amended since passage of the First Step Act, which allows inmates to file their own motions with the court irrespective of the BOP’s position. A majority of courts since passage of the First Step Act have held that courts have wide discretion to define “extraordinary and compelling reasons” beyond the definitions in 1B1.13.

The district court ultimately concluded that, regardless of whichever standard applied, and using its discretion to assume Rodd had proven extraordinary and compelling reasons, the court denied Rodd’s request based on a finding that his release was not supported by the factors under 3553(a), which the court must also consider when adjudicating a motion for compassionate release. Rodd appealed, arguing the district court failed to recognize its discretion to find extraordinary and compelling reasons.

On appeal, the Court affirmed the district court’s denial. It held that the district court had properly recognized its discretion by holding that, regardless of the issue of extraordinary and compelling reasons, release was not supported under 3553(a). The Court noted it was not deciding whether courts are bound by 1B1.13, but otherwise did not criticize or disfavor the district court’s exercise of discretion in assuming Rodd had met the definition for extraordinary and compelling reasons.

Appeal from the District of Minnesota

Opinion by Smith, joined by Melloy and Shepherd

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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