United States v. Jaramillo

Summary

The Second Circuit affirmed the denial of a pro se defendant's motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A) based on COVID-19 vulnerability. The court held that the district court did not abuse its discretion in finding no extraordinary and compelling reasons where the defendant initially failed to proffer specific medical conditions and later proffered conditions (sleep apnea, prediabetes, hypertension) that were not listed as high-risk by CDC guidelines at the time. The district court properly relied on CDC guidance in exercising its broad discretion, and the denial of reconsideration was also affirmed.

Holdings

1. The district court did not abuse its discretion in denying the motions because it was within its broad discretion to rely on CDC guidelines and to conclude that Jaramillo's medical conditions did not establish extraordinary and compelling reasons for a sentence reduction.

Questions Presented

1. Whether the district court abused its discretion in denying the motion for compassionate release based on vulnerability to COVID-19.
2. Whether the district court abused its discretion in denying the motion for reconsideration.

Disposition

affirmed