US v. Muhammad: Muhammad was convicted of distributing crack and powder cocaine and sentenced to 210 months in prison. He requested compassionate release from the warden at FCI Loretto, which was rejected less than three weeks later. Rather that pursue any appeal within the Bureau of Prisons of that denial, Muhammad filed a motion for compassionate release in district court. The Government resisted the request on the merits, but did not deny that Muhammad had met the requirements for seeking relief in court. Nonetheless, the district court denied Muhammad’s request because had not exhausted all his potential administrative remedies before seeking relief from the district court.
The Fourth Circuit reversed the district court’s decision and remanded to the district court to consider Muhammad’s request on the merits. Under the First Step Act, an inmate must first seek compassionate release from the Bureau of Prisons, but can go to court once that request is rejected or 30 days has passed. The court first held that the rule was not jurisdictional, but a claim processing rule, which the Government’s failure to argue in the district court could not waive. The court then held that although there were additional avenues of appeal for Muhammad in the Bureau of Prisons, once 30 days had elapsed from his request he was able to seek relief in court.
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