United States v. Hald, et al., No. 20-3195 (10th Cir. 2021)
Annotate this CaseDefendants James Hald, Monterial Wesley, and Walter Sands appealed the denials of their district-court motions for compassionate release under 18 U.S.C. 3582(c)(1)(A). They were among many prisoners who sought to be released from prison confinement during the COVID-19 pandemic. Each claimed that his underlying health conditions and mounting infections at his correctional facility satisfied the statute’s “extraordinary and compelling reasons” requirement for early release. Before granting a sentence reduction, the district court had to consider whether the factors set forth in 18 U.S.C. 3553(a) supported the reduction. The Tenth Circuit found each of the Defendants was denied relief by the United States District Court for the District of Kansas based on the court’s discretionary analysis of the section 3553(a) factors. The principal issue for the Tenth Circuit's review was whether, as argued by Hald and Sands, a district court was permitted to deny relief based on its assessment of the 3553(a) factors without first making a determination on the existence of “extraordinary and compelling reasons.” To this, the Tenth Circuit rejected the argument, holding that district courts were free to deny relief on the basis of any one of section 3582(c)(1)(A)’s requirements without considering the others. The Court also rejected the other arguments raised by Sands and Wesley. Accordingly, the denial of all three motions for compassionate release was affirmed.
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