US v. Centeno-Morales, No. 22-6607 (4th Cir. 2024)
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Angel Centeno-Morales, a federal prisoner with a long history of criminal offenses involving drugs and violence, filed a motion for compassionate release under 18 U.S.C. § 3582(c) after his wife, who was the primary caregiver for their minor son, died of COVID-19. Centeno-Morales argued that his wife’s death constituted an extraordinary and compelling reason for release and that a reassessment of the 18 U.S.C. § 3553(a) factors also favored his release given his changed circumstances and his post-sentencing rehabilitative conduct. The district court agreed that the death of Centeno-Morales’ wife constituted an extraordinary and compelling reason for relief, but found that the § 3553(a) factors strongly weighed in favor of his continued incarceration. Centeno-Morales appealed this decision.
The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court found that the district court did not abuse its discretion in denying Centeno-Morales' motion for compassionate release. The court found that the district court had properly evaluated the relevant § 3553(a) factors and provided sufficient reasoning for its decision. The court emphasized that Centeno-Morales had failed to meet his burden of persuasion to show that the § 3553(a) factors justified a modified sentence. The court further noted that the same judge who sentenced Centeno-Morales also ruled on his motion for compassionate release, which suggested the judge had a comprehensive understanding of Centeno-Morales' circumstances.
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