U.S. v. Williams

Defendant failed to exhaust his administrative remedies when seeking compassionate release from his 18-year sentence based on COVID-19 concerns, where defendant failed to submit said ground to Bureau of Prisons prior to filing instant request in District Ct. While Dist. Ct denied request on merits, record showed that defendant had filed with Bureau of Prisons request for compassionate release under 18 USC section 3582(c)(1)(A)(1) that asserted other grounds to support his request. Ct. of Appeals, though, found that defendant had failed to exhaust his administrative remedies (and thus could not bring instant request to District Ct.) where he failed to previously bring precise ground of COVID-19 concerns to Bureau of Prisons to consider.