United States of America v. Blades
2:10-cr-00164
N.D. Ind.Oct 5, 2021Background
- Williams was sentenced in 2011 to 262 months after pleading guilty to kidnapping (with ransom demand and firearm enhancement) and is incarcerated at FCI Pollock with a projected release date of Feb. 21, 2030.
- He moved pro se for compassionate release under the First Step Act, citing childhood asthma/COVID-19 risk and a need to assist his elderly mother; the BOP warden denied his request and the motion is administratively exhausted.
- The court treated the Sentencing Commission’s policy statement in U.S.S.G. § 1B1.13 as persuasive guidance (per Seventh Circuit precedent) but not binding.
- Court found Williams’ asthma and age (39), the zero active COVID-19 cases reported at FCI Pollock, and vaccine availability insufficient to establish an extraordinary and compelling medical risk.
- The court found caring for an elderly parent is not an extraordinary and compelling circumstance under the guiding policy and was not persuaded Williams is the only available caregiver.
- The court concluded that the § 3553(a) factors (serious, violent offense, ransom and firearm use, prior weapons convictions, on parole at time of offense) and community-safety concerns weigh against compassionate release, and denied the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of administrative remedies | Exhaustion satisfied (warden denied request) | Warden denial and 30-day lapse suffice | Exhaustion satisfied; court proceeds |
| Extraordinary and compelling: medical/COVID risk | Medical risk not extraordinary: asthma + age do not substantially impair self-care; FCI Pollock low/zero cases; vaccine available | Asthma increases COVID-19 complication risk, justifying release | Not extraordinary: low institutional risk and vaccine availability preclude relief |
| Extraordinary and compelling: family caregiver | Caring for elderly parent is not enumerated and is not sufficiently extraordinary; other caregivers likely available | Release needed so he can care for his elderly mother | Not extraordinary; court not convinced no other caregiver options |
| § 3553(a) factors / community danger | Serious violent kidnapping, ransom demand, firearm use, criminal history, and public-safety concerns weigh against release | Rehabilitation/compassionate reasons and family needs warrant reduction | § 3553(a) factors weigh against release; defendant poses community risk; motion denied |
Key Cases Cited
- United States v. Gunn, 980 F.3d 1178 (7th Cir. 2020) (§ 1B1.13 commentary is persuasive guidance for courts deciding compassionate-release motions)
- United States v. Raia, 954 F.3d 594 (3d Cir. 2020) (presence of COVID-19 in prisons alone does not justify compassionate release)
- United States v. Ugbah, 4 F.4th 595 (7th Cir. 2021) (availability of COVID-19 vaccine undermines most COVID-based compassionate-release claims)
- United States v. Broadfield, 5 F.4th 801 (7th Cir. 2021) (vaccine availability makes COVID-19 risk generally not an extraordinary and compelling reason for release)