U.S. v. Sanford

Dist. Ct. did not err in denying defendant’s motion for compassionate release under 18 USC section 3582(c)(1)(A) from his 15-year sentence imposed on his 2014 drug-trafficking offense, where said motion was based on defendant’s concerns regarding prison’s alleged inability to protect him from COVID-19 pandemic. While Dist. Ct. based ruling on merits of defendant’s motion, government raised timely contention that said motion should be denied based on defendant’s failure to exhaust administrative remedies within Bureau of Prisons prior to filing instant motion. Ct. of Appeals agreed that exhaustion requirement set forth in section 3582(c)(1)(A) is mandatory claim-processing rule and must be invoked when timely asserted, and further found that defendant had failed to exhaust his administrative remedies, where defendant had filed his motion for compassionate release just 3 days after prison’s warden had received defendant's request for compassionate release without waiting for either prison’s response (and pursuing any administrative appeal) or lapse of 30 days.