United States v. Ruvalcaba, No. 21-1064 (1st Cir. 2022)
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The First Circuit held that a district court, when adjudicating a prisoner-initiated motion for compassionate release, is not bound by the Sentencing Commission's current policy statement and may consider the First Step Act's (FSA) non-retroactive changes in sentencing law on an individualized basis to determine whether an extraordinary and compelling reason exists for compassionate release.
While Defendant was serving his sentence Congress passed the FSA. See Pub. L. No. 115-391, 132 Stat. 5194. The FSA reduced certain enhanced mandatory minimum penalties and modified the criteria for qualifying prior offenses and also amended the compassionate release statute, 18 U.S.C. 3582(c)(1)(A), to allow prisoners to file their own motions for compassionate release. Defendant subsequently moved for compassionate release. The district court denied the motion, concluding that the FSA's changes could not support an extraordinary and compelling reason for compassionate release. The First Circuit vacated the judgment below, holding that the court erred by concluding, as a matter of law, that the FSA's prospective changes to the mandatory minimum penalties could not, even when considered on an individualized basis, support a decision for compassionate release.
The court issued a subsequent related opinion or order on March 2, 2022.
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