U.S. v. Bridgewater

Dist. Ct. did not err in denying defendant's motion seeking compassionate release under First Step Act, 18 USC section 3582(c)(1)(A), even though defendant argued this his underlying medical conditions made him vulnerable to serious illness from spread of COVID-19 in prison, where Dist. Ct. found that defendant had agreed to waive his right to seek any modification of his sentence as part of his guilty plea deal. Moreover, Dist. Ct. could properly find that instant waiver was knowing and voluntary, and that it was enforceable against defendant (so as to preclude defendant from seeking instant relief or filing instant appeal) based upon his Rule 11 plea colloquy, and on fact that defendant had already received substantial benefit under his plea agreement. Fact that there was change in circumstances brought on by pandemic did not render defendant's prior waiver unknowing or involuntary, since said circumstances occurred after defendant's sentencing. Ct. of Appeals further rejected defendant's contention that instant waiver should not be enforced because it is contrary to public policy and unconscionable.