United States v. Broadfield, No. 20-2906 (7th Cir. 2021)Annotate this Case
Contending that his asthma and other breathing issues put him at extra risk should he contract COVID-19 while in prison, Broadfield applied for compassionate release under 18 U.S.C. 3582(c)(1)(A). For a prisoner who is younger than 70, relief depends on finding “extraordinary and compelling reasons.” The Seventh Circuit affirmed the denial of relief. Broadfield has not been convicted of a weapons offense, but the district court cited such an offense in its decision. However, section 3582(c)(1)(A) does not make a judicial finding of non-dangerousness essential to compassionate release. When Broadfield's application was denied, COVID-19 was a grave problem in America’s prisons. The Bureau of Prisons reports that 1,300 prisoners at FCI Seagoville, where Broadfield is confined, have been fully vaccinated against COVID-19. Because risk of COVID-19, which can bear especially hard on people with pre-existing breathing conditions, was Broadfield’s sole reason for seeking compassionate release, a remand would be pointless. A prisoner who remains at elevated risk because he has declined to be vaccinated cannot plausibly characterize that risk as an “extraordinary and compelling” justification for release. The federal judiciary need not accept a prisoner’s self-diagnosed skepticism about the vaccines as an adequate explanation for remaining unvaccinated, when the responsible agencies all deem vaccination safe and effective.