United States v. Carr

Summary

In *United States v. Carr*, the Tenth Circuit vacated the district court’s denial of compassionate release under 18 U.S.C. § 3582(c)(1)(A), holding that USSG §1B1.13 is not an “applicable” policy statement controlling the definition of “extraordinary and compelling reasons” for prisoner-initiated motions under the First Step Act. The district court had relied exclusively on §1B1.13’s “family circumstances” provision (requiring caretaker death or incapacitation) to deny relief based on the defendant’s eldest daughter’s changed ability to care for minor children. Following *McGee* and *Maumau*, the Tenth Circuit remanded for the district court to exercise independent discretion in defining “extraordinary and compelling reasons” and to consider the § 3553(a) factors if appropriate.

Holdings

1. USSG §1B1.13 is not presently an applicable policy statement that controls the definition of 'extraordinary and compelling reasons' when a prisoner initiates a § 3582(c)(1)(A) proceeding. District courts have independent discretion to define that term, subject to the requirement that any reduction be consistent with applicable policy statements.

Questions Presented

1. Whether USSG §1B1.13 is an applicable policy statement controlling the definition of 'extraordinary and compelling reasons' for prisoner-filed motions under 18 U.S.C. § 3582(c)(1)(A).
2. Whether the district court erred in relying on USSG §1B1.13 to deny Carr's motion for compassionate release without independently exercising its discretion.

Disposition

vacated