US v. Holley: In 2020 Holley was sentenced to 127 months in prison following a drug conviction. At the time he argued that the district court should consider his “poor physical condition,” which included kidney disease. In 2023, Holley sought compassionate release (first from the Bureau of Prisons, then from the district court) on the basis that he now suffered from “end-stage renal disease” requiring dialysis and, ultimately, a kidney transplant the he could not get while incarcerated. The district court denied the motion.
On appeal, the Fourth Circuit affirmed the denial of Holley’s compassionate release motion. The court held that Holley’s kidney failure was not a “terminal illness,” at least not categorically, and that the records provided by Holley showed he was not on an “end-of-life trajectory” and was “responding well to treatment.” It also affirmed the district court’s finding that the BoP was providing Holley with proper care, noting that nothing in the record showed Holley could not be considered for a transplant while incarcerated.
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