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September 1, 2022

First Circuit panel reiterates district courts' "broad discretion" and "holistic review" when resolving compassionate release motions

Today seems to be my day for catching up with circuit rulings regarding federal compassionate release decision-making.  My prior post today here about the Second Circuit's panel rulings limiting the consideration of certain arguments prompted a helpful reader to make sure I saw the recent First Circuit panel ruling running the other way.  In US v. Trenkler,  No. 21-1441 (1st Cir. Aug. 29, 2022) (available here), the panel stressed and reiterated a prior ruling setting out compassionate release rules:

Ruvalcaba convincingly set the standard for a district court reviewing a prisoner's proposed reasons for compassionate release, making it clear that district courts have the discretion to review prisoner-initiated motions by taking the holistic, any complex-of-circumstances approach we discussed earlier.  Indeed, this approach makes sense.  After all, it is possible that the whole may be greater than the sum of its parts, and reasons that might not do the trick on their own may combine to constitute circumstances that warrant a finding that the reasons proposed are, in the aggregate, extraordinary and compelling.  This is not to say that a district court must find a certain number of extraordinary and compelling reasons.  Rather, in conducting their reviews, district courts should be mindful of the holistic context of a defendant's individual case when deciding whether the defendant's circumstances satisfy the "extraordinary and compelling" standard -- "any complex of circumstances" contemplates that any number of reasons may suffice on a case-by-case basis, whether it's one, two, or ten.

I noted here the remarkable district court opinion last year in Trexler, and this case and so many others serve as a remarkable reminder of just how many different federal prisoners can cite to so many different circumstances when seeking a sentence modification.  A huge federal prison system necessarily creates a huge number of questions in the wake of the First Step Act's change to the compassionate release rules. 

September 1, 2022 at 06:03 PM | Permalink

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Translation: Lawless personal taste, mush-impersonating-argument, and legerdemain will now more-or-less completely displace determinate sentencing. Then people wonder why violent crime has been on the upswing since the First Step Act.

Posted by: Bill Otis | Sep 5, 2022 6:05:17 PM

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