United States v. Traylor, No. 21-1565 (6th Cir. 2021)
Annotate this CaseIn 2018, Traylor was convicted of conspiracy to commit health care fraud, 18 U.S.C. 1349, 1347; conspiracy to pay and receive healthcare kickbacks, 18 U.S.C. 371; and five counts of health care fraud, 18 U.S.C. 1347. The district court initially sentenced Traylor to 135 months’ imprisonment, which was reduced to 120 months at her recent resentencing. In a pro se third motion for a sentence reduction, Traylor argued that, due to her various health ailments (e.g., diabetes, sleep apnea, asthma, obesity, being a recent organ transplant recipient, and use of immunosuppressive therapy), she is susceptible to contracting and becoming severely ill from COVID-19 in prison. The Sixth Circuit affirmed the denial of the motion. Traylor did not demonstrate an extraordinary and compelling reason warranting a sentence reduction because she had received two doses of the Pfizer vaccine, significantly reducing her risk of contracting and becoming severely ill from COVID-19. The district court was not required to address the 18 U.S.C. 3553(a) factors and did not abuse its discretion by declining to do so.
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