United States v. Zullo, No. 19-3218 (2d Cir. 2020)
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Absent updated guidance from the Sentencing Commission, the First Step Act freed district courts to consider any potentially extraordinary and compelling reasons that a defendant might raise for compassionate release.
The Second Circuit vacated the district court's denial of compassionate release to defendant and remanded for further proceedings. In this case, the district court erroneously concluded that, despite the First Step Act's changes to compassionate release, the previously enacted USSG 1B1.13, Application Note 1(D) remained good law and limited the applicable circumstances the court could consider, without input from the Bureau of Prisons, to matters of poor health, old age, and family care needs. Rather, the court held that Application Note 1(D) does not apply to compassionate release motions brought directly to the district court by a defendant under the First Step Act.
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