Compassionate Release – In determining whether an inmate has shown “extraordinary and compelling reasons” warranting an inmate’s release or sentence reduction, non-retroactive changes in the law and facts that existed at the time of sentencing cannot constitute “extraordinary and compelling reasons.”
Ronald Hunter was sentenced to life in prison for murder. After serving 21 years in prison, a judge granted his motion for compassionate release based on the fact that Hunter was sentenced before the Guidelines were rendered advisory in United States v. Booker, Hunter’s rehabilitation efforts, the disparities between Hunter and his co-defendants, and his youth at the time of his sentencing.
On appeal, the Sixth Circuit held that this was an abuse of discretion and reversed. While the Court conceded that circuit precedent recognizes district courts have discretion in defining what constitutes “extraordinary and compelling reasons,” it held that this discretion is cabined in at least two ways: “non-retroactive changes in the law, whether alone or in combination with other personal factors,” and “facts that existed when the defendant was sentenced” cannot constitute “extraordinary and compelling reasons under 18 USC 3582(c)(1)(A). Since those could not be the basis, that left only Hunter’s rehabilitation, which standing alone cannot be the basis for a sentence reduction.
Appeal from the Eastern District of Michigan
Opinion by Guy, joined by Gibbons and Griffin
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