US v. Dwayne Ferguson, No. 21-6733 (4th Cir. 2022)
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While serving his federal sentence, Appellant asked the warden of the facility where he was incarcerated to file a motion for compassionate release on his behalf. After the warden denied his request, Appellant moved for compassionate release in federal district court. In addition to the arguments for compassionate release that Appellant presented to the warden, which were related to his medical condition, Appellant’s motion for compassionate release in the district court included arguments that his convictions and sentence were unlawful. The district court denied Appellant’s motion.
The Fourth Circuit affirmed. The court explained that while it agreed with Appellant that he was not required to include the arguments about his convictions and sentence in his request for compassionate release to the warden, the court agreed with the district court that Appellant cannot challenge the validity of his convictions and sentence through a compassionate release motion.
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