Dist. Ct. did not commit procedural error in denying defendant-prisoner's motion for compassionate release under 18 USC section 3582(c)(1)(A), even though Dist. Ct. failed to specifically address defendant's argument that his skin color elevated his risk for contracting COVID-19. While defendant cited to three articles discussing disparities in health care outcomes based on race, said articles did not support his motion for compassionate release, since: (1) said articles relied on multitude of broad societal factors that were not relevant to defendant's individual situation in prison; and (2) instant broad societal factors did not support proposition that black federal prisoners are at higher risk of contracting severe COVID-19 complications than federal prisoners of other races. As such, Dist. Ct. was not required to address instant argument when denying defendant's motion on other grounds. Also, defendant failed to submit any evidence that his perceived skin color rendered him especially vulnerable to virus in his prison.
Federal 7th Circuit Court
Criminal Court
Sentencing