Thursday, February 01, 2024

Court Affirms Denial of Compassionate Release on § 3553(a) Grounds

US v. Centeno-Morales: Centeno-Morales was convicted in 2015 on gun and firearm charges and sentenced to a total of 180 months in prison. In 2021, he filed a pro se motion for compassionate release based on his poor health and the increased risks related to COVID-19 in correctional facilities. He later supplemented the motion after the death of his wife, arguing that his son was now without a primary caregiver, an additional reason for relief. The Government conceded this constituted “extraordinary and compelling” reasons for relief, but argued Centeno-Morales should not be released based on the relevant sentencing factors from 18 U.S.C. § 3553(a).

On appeal, the Fourth Circuit affirmed the denial of Centeno-Morales’s motion for compassionate release. In doing so, the court noted the “broad discretion” that courts have in resolving such motions. In particular that is the case for judges who were the same judge that sentenced the defendant initially, as happened here. The court concluded that the district court did not overlook any of Centeno-Morales’s arguments and was not required to refute each one in detail. In addition, the court’s discussion of the § 3553(a) factors was sufficient.

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