United States v. Angel Centeno-Morales
90 F.4th 274
| 4th Cir. | 2024Background
- Angel Centeno-Morales, a federal prisoner with a significant history of drug and violent offenses, was convicted of methamphetamine distribution and firearm possession in furtherance of drug trafficking.
- He was sentenced to 180 months in prison after a guilty plea and has served about six years of his sentence.
- In May 2021, Centeno-Morales moved for compassionate release citing health concerns related to COVID-19, and later supplemented this with the argument that his wife, who was the primary caregiver for their minor son, had died from COVID-19.
- Both parties and the district court agreed the wife’s death constituted an extraordinary and compelling reason for possible release under 18 U.S.C. § 3582(c)(1)(A), but the Government argued, and the district court found, that the sentencing factors under 18 U.S.C. § 3553(a) outweighed this circumstance.
- The district court denied compassionate release, emphasizing the seriousness of Centeno-Morales' offenses, his criminal history, his conduct while incarcerated, and public safety concerns.
- Centeno-Morales appealed, arguing the district court failed to adequately weigh post-sentencing rehabilitation and the change in family circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether extraordinary and compelling reasons support release | Death of wife as primary caregiver is an extraordinary and compelling reason | Concedes this ground, but focuses on other statutory criteria | Yes, this standard is met |
| Whether § 3553(a) factors weigh in favor of release | Rehabilitation, disciplinary record, child’s need justify early release | Seriousness of offense, danger to public, prior conduct, weak rehabilitation | § 3553(a) factors weigh against release |
| Whether district court sufficiently considered mitigation | Court ignored key rehabilitation and family hardship arguments | Court considered all arguments; thorough explanation not required without significant evidence | Court sufficiently considered all required arguments |
| Whether explanation required more detail under Fourth Circuit precedent | Insufficient detail given individual circumstances | Extensive explanation not required absent substantial mitigation evidence | No detailed explanation required; court’s process adequate |
Key Cases Cited
- United States v. Hargrove, 30 F.4th 189 (4th Cir. 2022) (describes two-step analysis for compassionate release under § 3582(c)(1)(A))
- United States v. High, 997 F.3d 181 (4th Cir. 2021) (district courts must provide sufficient reasoning to enable appellate review; detailed explanations only required in exceptional circumstances)
- United States v. Bethea, 54 F.4th 826 (4th Cir. 2022) (abuse of discretion review; significance of same judge handling sentencing and release motions)
- United States v. Martin, 916 F.3d 389 (4th Cir. 2019) (detailed explanation required only with substantial new mitigating post-sentencing evidence)