US v. Washington: In 2020, Washington was convicted on two drugs charges and sentenced as a career offender, ultimately receiving a downward variance sentence of 96 months in prison. In 2022, he filed a motion for compassionate release arguing that, if sentenced then, he would no longer be a career offender and would face a Guideline range of only 24 to 30 months in prison. the district court agreed that was a “compelling and extraordinary” basis for a reduced sentence, but ultimately denied Washington’s request after reviewing the §3553(a) factors.
A divided Fourth Circuit affirmed the denial of Washington’s compassionate release motion. The court rejected Washington’s arguments that the district court did not adequately consider the sentencing disparity and focused unduly on his criminal history (while also being “too dismissive of his rehabilitative efforts”). In doing so, the court noted that the district court in these cases is not required to engage with the defendant’s arguments with the same detail as in an original sentencing. Ultimately, the record showed that the district court “engaged with Washington’s arguments, articulated what factors it found important or unimportant to its decision, and stated the grounds for denying the requested relief.” That was enough.
Judge Berner dissented, arguing that once a district court finds extraordinary and compelling reasons exist to support a reduction it must “then assess the impact of that finding in relation to the relevant” §3553(a) factors.
No comments:
Post a Comment