USA V. JOEL WRIGHT, No. 20-50361 (9th Cir. 2022)
Annotate this CaseDefendant contended that the district court abused its discretion by denying his motion based on the dangerousness finding imposed by U.S.S.G. Section 1B1.13. In United States v. Aruda, the Ninth Circuit held that the current version of Section 1B1.13 is not an applicable policy statement for Section 3582(c)(1)(A)(i) motions filed by a defendant. Following Aruda, while the Sentencing Commission’s statements in Section 1B1.13 may inform a district court’s discretion for Section 3582(c)(1)(A)(i) motions filed by a defendant, they cannot be treated as binding constraints on the court’s analysis. Here the Ninth Circuit wrote that the district court did precisely what Aruda proscribes: it denied Defendant’s motion by holding that he failed to demonstrate that he is “not a danger to others or [to] the community” pursuant to Section 1B1.13. The court wrote that this holding is an abuse of discretion.
Court Description: Criminal Law. The panel affirmed the district court’s denial of Joel Alexander Wright’s motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), in which Wright requested a reduction to time served and immediate release, or, in the alternative, home detention for the balance of his sentence. Wright contended that the district court abused its discretion by denying his motion based on the dangerousness finding imposed by U.S.S.G. § 1B1.13. In United States v. Aruda, this Court held that the current version of § 1B1.13 is not an applicable policy statement for § 3582(c)(1)(A)(i) motions filed by a defendant. Following Aruda, while the Sentencing Commission’s statements in § 1B1.13 may inform a district court’s discretion for § 3582(c)(1)(A)(i) motions filed by a defendant, they cannot be treated as binding constraints on the court’s analysis. Here, the district court did precisely what Aruda proscribes: it denied Wright’s motion by holding that he failed to demonstrate that he is “not a danger to others or [to] the community” pursuant to § 1B1.13. The panel wrote that this holding is an abuse of discretion. The panel held that Aruda error is harmless if the court properly relied on 18 U.S.C. § 3553(a) sentencing factors as an alternative basis for its denial of a compassionate release motion, as the district court did here when it held in the alternative that the 18 U.S.C. § 3553(a) sentencing factors UNITED STATES V. WRIGHT 3 weighed “squarely against” granting Wright’s compassionate release motion. The panel wrote that although Wright may take issue with the balance the court struck, mere disagreement with the weight of these factors does not amount to an abuse of discretion. The panel therefore held that the district court’s reliance on § 1B1.13 was harmless error. Wright also contended that the district court abused its discretion by failing to respond to his alternative request to serve the rest of his sentence under home confinement. The panel held that the district court adequately addressed that request, as Wright did not adduce any evidence or advance any arguments in support of it, which rested on the same legal and factual foundation as his request for a time-served sentence. Given the arguments made and the judge’s knowledge of the record, the panel was satisfied that the judge adequately considered Wright’s motion and had a reasoned basis for exercising his own legal decision-making authority.
The court issued a subsequent related opinion or order on August 29, 2022.
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