US v. Rayco Bethea, No. 21-6602 (4th Cir. 2022)
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Defendant was resentenced to a 188-month term of imprisonment, the district court denied his motion for compassionate release under 18 U.S.C. Section 3582(c)(1)(A)(i) (authorizing district courts to “reduce the term of imprisonment” on finding “extraordinary and compelling reasons” to do so). In his Section 3582(c) motion, Defendant argued that he has significant health issues that place him at an elevated risk of serious illness were he to contract COVID-19 and that the relevant Section 3553(a) factors warrant his immediate release. The Government opposed Defendant’s motion, citing a number of measures that the Federal Bureau of Prisons (“BOP”) has taken to protect inmates, like Defendant, from COVID-19. Further, it argued that the sentencing factors set forth in 18 U.S.C. Section 3553(a) weigh against reducing Defendant’s term of imprisonment. On appeal, Defendant contends the district court abused its discretion by essentially applying a per se rule that individuals vaccinated against COVID-19 were ineligible for Section 3582(c) release.
The Fourth Circuit affirmed the finding that both Defendant’s arguments misrepresent the record and are without merit. The court explained that the district court considered numerous Section 3553(a) factors, responding both to Defendant’s arguments for release and the Government’s arguments against release. Critically, Defendant’s resentencing and his motion for compassionate release both took place in front of the same district judge on the same day during the same hearing. Nearly all the considerations that Defendant claimed were absent from the court’s compassionate-release analysis were comprehensively addressed immediately prior during the hearing’s resentencing phase.
This opinion or order relates to an opinion or order originally issued on December 13, 2022.
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