U.S. v. Williams

Dist. Ct. did not err in denying defendant’s request for compassionate release under 18 USC section 3582(c)(1), where basis for said request was defendant’s contention that Dist. Ct. had committed legal error at his sentencing by treating his Illinois prior conviction for delivery of cocaine as “serious drug felony” that made him eligible for enhanced minimum sentence of 10 years under 21 USC section 841(b)(1)(B). Under Thacker, 4 F.4th 569, alleged legal errors are not addressable under compassionate release provisions, especially where defendant had other avenues of potential relief under section 2255. Moreover, although defendant raised for first time other arguments to support his request for compassionate release, he could not pursue them because he had failed to first raise them with Bureau of Prisons, as required under 18 USC section 3582(c)(1)(A). Ct. also observed that government could raise failure to exhaust administrative remedies defense for first time in Ct. of Appeals, where government had no opportunity to raise it in Dist. Ct.