United States v. Ruffin, No. 20-5748 (6th Cir. 2020)
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Ruffin was convicted for a drug-trafficking scheme. The court calculated Ruffin’s guidelines range as 30 years’ to life imprisonment. Ruffin had a blood disorder that had caused him to suffer four strokes. He regularly used a wheelchair due to paralysis on his left side. Ruffin suffers from heart problems, high blood pressure, high cholesterol, and blood clots. When balancing the sentencing factors in 18 U.S.C. 3553(a), the court expressed concern over Ruffin’s witness-tampering and prior convictions.
Ruffin has served 10 years of his 25-year sentence. In May 2020, Ruffin sought early “compassionate release” under 18 U.S.C. 3582(c)(1)(A), claiming that his health conditions exacerbate the risks from COVID-19, creating “extraordinary and compelling reasons” for relief. The court initially noted that the Sentencing Commission defined “extraordinary and compelling reasons” for relief to cover only medical conditions that substantially diminish a defendant’s ability to provide “self-care” in prison, U.S.S.G. 1B1.13 cmt. n.1(A)(ii). Next, the court noted that the Commission’s guidance required Ruffin to show that, if released, he would not be a “danger” to the community, section 1B1.13(2), and noted his extensive criminal record. Lastly, the court held that section 3553(a)'s factors counseled against reducing the sentence. Ruffin argued that, after the First Step Act, courts may find extraordinary and compelling reasons beyond those listed in the commentary.
The Sixth Circuit affirmed the denial of relief. Even when extraordinary and compelling reasons exist, the statute gives courts discretion to deny relief under a balancing of section 3553(a)'s sentencing factors. The district court denied relief not just because no extraordinary and compelling reasons existed, but also because those factors weighed against his release, and did not abuse its discretion when balancing those factors.
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