United States v. Saladino, No. 20-1563 (2d Cir. 2021)
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The Second Circuit vacated the district court's denial of defendant's motion for compassionate release, holding that 18 U.S.C. 3582(c)(1)(A)'s exhaustion requirement is not jurisdictional.
The court clarified that the administrative exhaustion requirement is not a jurisdictional limitation on a court's power to consider an inmate's motion for compassionate release. Rather, section 3582(c)(1)(A)'s exhaustion requirement is a claim-processing rule that may be waived or forfeited by the government. In this case, the government withdrew any defense based on defendant's prior failure to exhaust his administrative remedies. The court remanded for the district court to consider his motion on the merits.
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