United States v. Clenista, No. 21-273 (2d Cir. 2022)Annotate this Case
In 2016, Clenista, then on supervised release for another federal methamphetamine-distribution conviction pleaded guilty to conspiracy to distribute and possess with intent to distribute 500 or more grams of methamphetamine, 21 U.S.C. 846, 841(a)(1), 841(b)(1)(A). The court sentenced him to the mandatory minimum term of 120 months’ imprisonment, followed by five years of supervised release. Clenista moved for compassionate release in 2020, 18 U.S.C. 3582(c)(1).
The district court denied Clenista's motion. The court assumed that Clenista had shown extraordinary and compelling circumstances, but ultimately determined that the 18 U.S.C. 3553(a) factors weighed against granting compassionate release. The Second Circuit affirmed. While defendants who received a mandatory minimum sentence are eligible for a sentence reduction under section 3582(c)(1), the district court did not abuse its discretion when it placed weight on the need to recognize the seriousness of Clenista's offense, to provide a just punishment, to protect the public from further such activity and Clenista’s characteristics, rather than on changed circumstances, such as Clenista’s age and health and the pandemic.