United States v. Andrews

The defendant is serving a sentence, which is more than three centuries long for his role in 13 gunpoint robberies committed when he was 19 years old. He filed a motion for compassionate release pursuant to the First Step Act. The defendant sought relief, pointing to the recent changes to the mandatory minimum laws and the duration of his sentence. He also noted his rehabilitation in prison, his relatively young age at the time of his offense, the government’s decision to charge him with thirteen § 924(c) counts, and his alleged susceptibility to COVID-19. He claimed that, together, those reasons were extraordinary and compelling under the compassionate-release statute. The District Court disagreed and denied the motion. The Third Circuit affirmed, holding that the District Court did not err when it interpreted and applied the phrase “extraordinary and compelling reasons” under 18 U.S.C. § 3582(c)(1)(A)(i). The District Court also did not err when it concluded that the duration of the sentence and the nonretroactive changes to mandatory minimums could not be extraordinary and compelling reasons warranting sentence reduction. Finally, the District Court did not abuse its discretion in determining that the defendant’s other reasons fell short of the extraordinary-and-compelling requirement.

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