United States v. Arroyo Marrero, 1:21-cr-00043

Background

Felix Juan Arroyo-Marrero pled guilty to conspiracy to distribute 500 grams or more of cocaine, acting as a leader in a Delaware cocaine distribution conspiracy.
He was arrested after law enforcement intercepted drug shipments, found weapons in his possession, and uncovered preparations for a possible retaliatory shooting.
Arroyo-Marrero received a downward variance at sentencing (to 88 months imprisonment) specifically due to his family's circumstances (wife with cancer and father with Alzheimer's).
The court explicitly factored in these compassionate circumstances at sentencing and informed Arroyo-Marrero he would deny future compassionate release motions based on the same facts.
Less than a year after sentencing, Arroyo-Marrero moved pro se for sentence reduction under 18 U.S.C. § 3582(c)(1)(A), arguing for compassionate release due to his caregiving needs under new Sentencing Guidelines Amendment 814.
The government opposed the motion, and the court reviewed whether the required showing of "extraordinary and compelling reasons" and sole caregiver status was met.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are there "extraordinary and compelling reasons" under § 3582(c)(1)(A) for sentence reduction?	Arroyo-Marrero: His wife's cancer and his father's Alzheimer's make him the only available caregiver, now recognized under Amendment 814 as extraordinary and compelling.	Government: Insufficient evidence of wife’s incapacitation and that Arroyo-Marrero is the only available caregiver; these circumstances were already considered at sentencing.	Motion denied; insufficient evidentiary showing and circumstances already considered in original sentencing.
Does Amendment 814 to the Sentencing Guidelines create new grounds for relief in this context?	Amendment recognizes incapacitation of spouse/parent as "extraordinary and compelling" grounds for relief.	Government: Even under Amendment 814, Arroyo-Marrero's evidence of incapacity and sole caregiving status is lacking.	Court agrees; no adequate documentation for incapacity/care needs.
Can arguments considered at sentencing be relitigated for compassionate release?	No new facts, but urges reconsideration under the new guideline.	Previously warned Arroyo-Marrero that sentence already reflected compassionate circumstances.	Court adheres to statements at sentencing: prior consideration bars further reduction based on same facts.
Has Arroyo-Marrero met his burden for compassionate release under the statute?	Yes; he claims to be the only caregiver facing extraordinary family hardship.	No; documentary proof inadequate, other care options unexcluded.	Court holds Arroyo-Marrero did not meet his burden.

Key Cases Cited

Dillon v. United States, 560 U.S. 817 (2010) (discusses that district courts generally cannot modify imposed sentences except as authorized by statute)
United States v. Andrews, 12 F.4th 255 (3d Cir. 2021) (notes First Step Act added procedure for prisoner-initiated motions but did not change the standard for compassionate release)