United States v. Claude, No. 20-3563 (3d Cir. 2021)
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In 2014, Claude, convicted of bank fraud, access device fraud, aggravated identity theft, and currency offenses, was sentenced to 232 months’ imprisonment. In 2020, Claude sought compassionate release under 18 U.S.C. 3582(c)(1)(A)(i), citing “extraordinary and compelling circumstances” arising from his purported “substantial assistance to the D.E.A. of New Jersey.” Claude alleged that, four years earlier, he provided crucial assistance, which allowed the government to “bust[] someone with multiple kilos of cocaine” and “locat[e] a cell phone that was part of a child pornography indictment.” The government filed a Rule 35(b) motion on behalf of another prisoner who, Claude insists, “reap[ed] the benefits” of his efforts, resulting in a “gross disparity” between his sentence and that of the undeserving cooperator. The government asserted that his purported assistance was neither substantial nor welcomed.
The district court denied Claude’s motion, stating that a reduction of sentence for post-sentencing cooperation requires a Rule 35 motion from the government’ and cannot be raised by a defendant through a section 3582(c)(1)(A) motion for compassionate release. While the First Step Act made substantial changes to the procedures applicable to compassionate release motiongs based on extraordinary and compelling reasons, Congress made no changes to Rule 35, which governs sentence reductions based on substantial assistance. The Third Circuit affirmed. Substantial assistance is not itself an extraordinary and compelling reason warranting compassionate release under section 3582(c)(1)(A)(i).
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