USA v. Curtis Jenkins, No. 21-3089 (D.C. Cir. 2022)
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Appellant agreed to plead guilty to one section 924(c) charge and one cocaine possession charge in exchange for dismissal of the remaining four charges. The parties agreed that the career offender sentencing guideline, U.S.S.G. Section 4B1.1(a), applied. The district court sentenced Appellant to eight years. Appellant waived any right to challenge the sentence on direct appeal or by motion under 28 U.S.C. Section 2255, except to the extent such a motion was based on newly discovered evidence or a claim of ineffective assistance of counsel. Appellant filed a motion for compassionate release. He argued that the narrowed stacking provision, the commission of a Winstead error to trigger the career offender guideline, and the pre-Borden threat of a 15-year minimum sentence under ACCA were extraordinary and compelling circumstances warranting early release.
The DC Circuit affirmed and held that the district court properly denied Appellant’s motion. The court explained that Appellant is correct that factors may sometimes become extraordinary and compelling when considered together. And here the district court did not explicitly address the combined weight of Appellant’s arguments. Still, the court did not abuse its discretion. It correctly determined that Appellant’s arguments factors about the intervening changes in sentencing law were legally irrelevant to the compassionate-release determination. That left only arguments about his own health and family circumstances. The court reasonably found that these circumstances were minimally significant, so it did not need to say explicitly that their combined force did not rise to the level of extraordinary and compelling circumstances.
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