Summary
The Ninth Circuit held that the current version of U.S.S.G. § 1B1.13 is not an applicable policy statement governing compassionate-release motions filed by defendants under 18 U.S.C. § 3582(c)(1)(A). Because the district court treated § 1B1.13 as binding when denying Patricia Aruda’s motion, the court vacated the order and remanded for reconsideration under the correct legal standard.
Topics
Practice areas
Questions Presented
- Whether U.S.S.G. § 1B1.13 is an applicable and binding Sentencing Commission policy statement for a compassionate-release motion filed by a defendant under 18 U.S.C. § 3582(c)(1)(A).
- Whether the district court abused its discretion by treating U.S.S.G. § 1B1.13 as binding when denying Aruda's compassionate-release motion.
- What standard of review applies to sentence-reduction decisions under 18 U.S.C. § 3582(c)(1).
Holdings
- The current version of U.S.S.G. § 1B1.13 is not an applicable Sentencing Commission policy statement for motions filed by defendants under 18 U.S.C. § 3582(c)(1)(A).
- Although U.S.S.G. § 1B1.13 may inform a district court's discretion in deciding a defendant-filed compassionate-release motion, it is not binding.
- The Ninth Circuit reviews sentence-reduction decisions under 18 U.S.C. § 3582(c)(1) for abuse of discretion and reviews statutory interpretation de novo.
Key quotations
“We agree with the persuasive decisions of our sister circuits and also hold that the current version of U.S.S.G. § 1B1.13 is not an “applicable policy statement[]” for 18 U.S.C. § 3582(c)(1)(A) motions filed by a defendant.” (11)
“The Sentencing Commission’s statements in U.S.S.G. § 1B1.13 may inform a district court’s discretion for § 3582(c)(1)(A) motions filed by a defendant, but they are not binding.” (11)
Factual background
In 2015, Patricia Aruda pleaded guilty to possessing with intent to distribute 500 grams or more of a substance containing methamphetamine and was sentenced to 130 months' imprisonment plus five years of supervised release. In June 2020, she sought compassionate release because of COVID-19 conditions at her facility and medical conditions that allegedly increased her risk of serious complications. The district court accepted that her circumstances constituted extraordinary and compelling reasons but denied release based on the § 3553(a) factors and the danger-to-the-community provision in U.S.S.G. § 1B1.13.
Procedural history
Aruda pleaded guilty in the District of Hawaii to possession with intent to distribute methamphetamine and received a 130-month prison sentence followed by five years of supervised release. In June 2020, she moved for compassionate release based on COVID-19 risks and medical conditions. The district court found extraordinary and compelling reasons but denied relief after treating U.S.S.G. § 1B1.13 as binding and relying on the § 3553(a) factors and dangerousness. The Ninth Circuit vacated and remanded for reconsideration under the correct legal standard.
Remand instructions
The district court must reassess Aruda's compassionate-release motion under the correct legal standard, treating U.S.S.G. § 1B1.13 as nonbinding and considering any appropriate circumstances, including her allegation that she contracted and recovered from COVID-19.