U.S. v. Jackson

Dist. Ct. did not err in denying defendant's request for compassionate release from prison under 18 USC section 3582(c)(1) under circumstances, where: (1) defendant received life sentence without parole in 1986; and (2) defendant claimed that said release was warranted given his medical condition and being required to live in close quarters during SARS-CoV-2 pandemic. Defendant was convicted of underlying crimes prior to November 1, 1987 effective date of Sentencing Reform Act of 1984, and (2) compassionate release provisions of section 3582 applies only to offenses committed after effective date of Sentencing Reform Act. As such, given defendant's no-parole sentence, which lacked minimum term of years, defendant retained only possibility of commutation by President in order to obtain release from prison. Ct. rejected defendant's argument that 2018 enactment of First Step Act essentially rendered section 3582(c)(1) applicable to individuals convicted of offenses prior to November of 1987.