United States v. Williams, No. 22-1981 (7th Cir. 2023)
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Williams sought compassionate release under 18 U.S.C. 3582(c)(1), citing as “extraordinary and compelling” circumstances the fact that a district court treated him as having a prior conviction for unlawful drug delivery, which increased his minimum sentence, 21 U.S.C. 841(b)(1)(B), while his Illinois conviction for delivery of cocaine did not satisfy the criteria of a “serious drug felony.”
The Seventh Circuit rejected that argument, noting its own precedent. Section 3582(c)(1) addresses some new fact about an inmate’s health or family status, or an equivalent post-conviction development, not a purely legal contention for which statutes specify other avenues of relief with distinct requirements, such as the time limits in 28 U.S.C. 2255(f) or the need for a declaration by the Sentencing Commission that a revision to a Guideline applies retroactively. There is nothing “extraordinary” about a legal error and the law provides methods other than compassionate release for dealing with those claims.
Williams also argued that he has a spotless conduct record in prison, has completed educational programs that will allow him to participate in society, and has a greater risk of contracting COVID-19 and other diseases in prison. The court rejected those claims for failure to exhaust administrative remedies by presenting them to the Bureau of Prisons.
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