US v. High: In 2019, High was sentenced to 84 months in prison following his conviction for distributing crack cocaine. In 2020, he filed a motion for compassionate release, arguing that he had a history of heart conditions that left him particularly vulnerable to serious effects of COVID-19 and that it was likely he would contract the disease in the institution where he was incarcerated. The district court denied the motion, relying on the 3553(a) factors and noting that High had only begun to serve his sentence, that the sentence was still “sufficient, but not greater than necessary” to support the purposes of sentencing, and that having “reviewed and considered the relevant factors” relief was not warranted.
The district court affirmed the denial of High’s request for compassionate release. In doing so, the court noted that High’s appeal “does not take serious issue with the substance of the district court’s decision but rather focuses on the procedure the court followed in explaining its decision.” Applying recent Supreme Court precedent, the court concluded that there was no requirement in such proceedings that the district court acknowledge and address all arguments made by the defendant. In this case, the same district court judge who denied the motion was the one who imposed the original sentence, the district court “implicitly responded to High’s straightforward motion,” and it identified “rational and legitimate” reasons for rejecting High’s request. The court distinguished it’s recent Martin decision by pointing out that there was no similar “mountain of new mitigating evidence” in this case, given that a short amount of time had passed since High was sentenced.
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