United States v. Stewart, No. 22-2770 (3d Cir. 2023)
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In 2022, Stewart, serving a life sentence for drug trafficking, racketeering, and attempted money laundering, moved for compassionate release, 18 U.S.C. 3582(c)(1)(A)(i). He cited his record of rehabilitation, the risks posed by the COVID-19 pandemic, and his status as a survivor of attempted prison rape as extraordinary and compelling reasons warranting a sentence reduction.
The district court found that there were no “extraordinary and compelling” circumstances and declined to analyze whether Stewart’s release would be consistent with the section 3553(a) sentencing factors. The Third Circuit affirmed the denial of relief. Section 3582 does not define “extraordinary and compelling,” so courts may consult the Sentencing Commission’s policy statements—which are non-binding in the context of prisoner-initiated motions—“to form a working definition” of the phrase. The Third Circuit has held that neither the length of a lawfully imposed sentence nor any nonretroactive change to mandatory minimum sentences establishes “extraordinary and compelling” circumstances warranting release but may be relevant “at the next step of the analysis,” when the court weighs the section 3553(a) factors.
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