United States v. Anthony Lewis
21-11197
| 11th Cir. | Nov 12, 2021Background
- Anthony Lewis, a federal inmate, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), citing high COVID-19 risk from asthma, partial blindness, chronic pain, and glaucoma.
- Lewis argued his prison education, exemplary behavior, work record, rehabilitation, and a post-release plan showed he was not a danger and that § 3553(a) factors favored reduction.
- The government opposed the motion; the district court assumed Lewis showed extraordinary and compelling reasons but denied relief on § 3553(a) grounds and alternatively found Lewis would be dangerous if released.
- The district court emphasized Lewis’s extensive criminal history: convictions for attempted murder, attempted felony murder of a police officer, resisting an officer with violence, felon-in-possession counts, and participation (while on probation) in a year-long drug conspiracy involving large quantities of cocaine, other drugs, stash/trap houses, and multiple firearms.
- The court noted Lewis’s status as a career offender and the seriousness of his offense, concluding that serving the remainder of his 132-month sentence was necessary to reflect seriousness, provide deterrence, and protect the public.
- The Eleventh Circuit reviewed for abuse of discretion and affirmed the district court’s denial of compassionate release.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in denying compassionate release | Lewis: COVID risk + medical conditions and rehabilitation make release warranted | Gov: § 3553(a) factors and public-safety concerns outweigh medical risks | No abuse of discretion; denial affirmed |
| Whether § 3553(a) sentencing factors supported a sentence reduction | Lewis: rehabilitation, education, work, and post-release plan weigh in favor | District court/Gov: offense seriousness, criminal history, career-offender status weigh against reduction | Court upheld district court’s weighing in favor of continued imprisonment |
| Whether Lewis would pose a danger to the community if released | Lewis: exemplary prison conduct shows he is not dangerous | District court/Gov: lengthy violent history, firearms, attempted murders and massive drug conspiracy indicate danger | District court reasonably found Lewis would be a danger; alternative basis for denial affirmed |
Key Cases Cited
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (standard of review and abuse-of-discretion framework for compassionate-release denials)
- Cordoba v. DIRECTV, LLC, 942 F.3d 1259 (11th Cir. 2019) (clarifies what constitutes an abuse of discretion)
- United States v. Kuhlman, 711 F.3d 1321 (11th Cir. 2013) (district court may weigh offense seriousness and criminal history heavily when denying relief)