U.S. v. Vaughn

Dist. Ct. did not err in denying defendant’s request for compassionate release under 18 USC section 3582(c)(1), where record showed that: (1) defendant had been sentenced to 262-month sentence on heroin-related offenses; and (2) defendant asserted that his asthma, obesity and hypertension put him at extra risk of contracting COVID-19 while in prison, that his sentence was excessive in light of current legal standards, and that he had taken classes that demonstrated his rehabilitation. Defendant failed to present medical evidence indicating that his combination of medical conditions placed him at greater risk of contracting COVID-19 while in prison. Defendant similarly failed to present data establishing that his completion of prison courses reliably put him and other prisoners on path to law-abiding life. Moreover, record was unclear that defendant would receive lower sentencing under current legal standards, where his sentence was based on finding that he was career offender under sentencing guidelines. Ct. further noted that defendant’s arguments, when considered collectively, would still not constitute extraordinary and compelling reason to grant compassionate release.