Appeal Denied with Insufficient Evidence

For every compassionate release case that has been granted, many have been denied.  Many denials have been very brief.  This examines a case where the denial has insufficient evidence to support the denial.  The Fourth Circuit took up an appeal of a denial of one such motion in Sprague, 20-6335.

Sprague's Original Conviction

Sprague is serving a sentence that is at least in part enhanced by his “stacked 924c” convictions.  He filed a motion for a compassionate release under 18 USC 3582 and raised several arguments.  “The district court denied Sprague’s motion by text order and provided no explanation for the denial.”

Appeal Based on Insufficient Evidence

As we know, the standard of review for an appeal of the denial of a compassionate release motion is “abuse of discretion,” which is “when [a court] acts arbitrarily or irrationally, fails to consider judicially recognized factors constraining its exercise of discretion, relies on erroneous factual or legal premises, or commits an error of law.”  Further, “A district court also abuses its discretion ‘when it ignores unrebutted, legally significant evidence.’”

The court indicated that because a district court is obliged to  “consider the 18 U.S.C. § 3553(a) sentencing factors “to the extent that they are applicable,” and may grant a sentence reduction if it is “consistent with applicable policy statements issued by the [United States] Sentencing Commission[,]” and because there is no applicable policy statement governing compassionate release motions filed by defendants, “district courts are empowered to consider any extraordinary and compelling reason for release that a defendant might raise.”

“Here, the district court denied Sprague’s motion in a text order devoid of explanation. As it is unclear whether the district court considered the § 3553(a) sentencing factors or Sprague’s arguments in favor of a sentence reduction, we are unable to conduct meaningful appellate review.”

In other words, the district court can’t even determine if there was an abuse of discretion.  As a result, the Fourth Circuit vacated the ruling of the District Court and sent the case back down for further review.

Jeremy's Notes

As you know, in most situations there are three things that must be considered when the court is considering a compassionate release:

-Whether the petitioner has shown extraordinary and compelling circumstances
-Whether the petitioner is a danger to others (however, see the 6th Circuit)
-Whether the 3553(a) sentencing factors warrant a release at the time of the motion.

If a district court is going to deny a compassionate release then they should explain which one of these criteria the petitioner doesn't meet and why they don't.  It is not enough for the court to deny a compassionate release without reasoning even in this time where the district courts are getting many more compassionate release motions than they normally would.

If your judge did not give any reasoning at all as to why your compassionate release was denied then an appeal would be warranted.