United States v. Bradley, No. 23-1223 (10th Cir. 2024)
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In 2015, Jason Vincent Bradley was convicted on multiple counts related to firearm possession and drug trafficking. He was sentenced to concurrent 120-month sentences on three counts and a consecutive 60-month sentence on the fourth count, followed by three years of supervised release. In 2021, Bradley filed a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing the need to care for his minor children due to his mother's ill health and his own health conditions that increased his risk of serious illness from COVID-19.
The United States District Court for the District of Colorado denied Bradley's motion for compassionate release. The court acknowledged Bradley's claims of extraordinary and compelling reasons for release but found that the factors set forth in 18 U.S.C. § 3553(a) did not support a sentence reduction. Bradley appealed the decision, arguing that the district court erred by not considering his proffered extraordinary and compelling reasons for release as part of its § 3553(a) analysis and by not accounting for his post-sentencing conduct and rehabilitation.
The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The appellate court found that Bradley had waived his first argument by not raising it in the lower court. Regarding his second argument, the court found that the district court had considered Bradley's post-sentencing conduct and rehabilitation, and it had provided a rationale for its decision. The court concluded that the district court did not abuse its discretion in denying Bradley's motion for compassionate release.
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