United States v. BELANGER
1:15-cr-00072-JDL
| D. Me. | Jun 30, 2025Background
- Kelli Mujo was convicted in 2016 for drug offenses and sentenced to 168 months in prison.
- She previously moved for compassionate release in 2022 due to medical issues and her desire to care for her special-needs adult son; the court denied this in January 2023 but allowed her to renew if circumstances changed.
- In April 2025, Mujo filed a second motion, citing a new cancer diagnosis and the argument that she required treatment unavailable or inferior in prison.
- The government opposed, noting Mujo’s upcoming release to home confinement and her refusal to accept cancer treatment while incarcerated.
- The court considered whether Mujo exhausted administrative remedies for this new motion and whether her medical and family circumstances now constituted “extraordinary and compelling reasons” for release.
- Defendant is presently scheduled for home confinement on July 10, 2025, with full release projected for July 2027.
Issues
| Issue | Mujo's Argument | Government's Argument | Held |
|---|---|---|---|
| Administrative exhaustion | Claimed prior requests and that further exhaustion unnecessary | Argued no new administrative request made | Mujo failed to properly exhaust remedies; motion denied on this ground |
| Medical circumstances (compassionate release) | Cancer diagnosis and related health issues warrant release | Treatment available; Mujo refused care; near home confinement | New diagnosis not sufficiently extraordinary; imminent home confinement negates need |
| Family circumstances (son's care) | Needs to advocate for and care for son with special needs | No qualifying new incapacity or death of caregiver; public care dissatisfaction not extraordinary | Not extraordinary under policy; no new facts or legal support |
| Court’s prior invitation to renew | Allowed to file new motion if circumstances changed | Procedural rules, including exhaustion, still apply | Court did not waive exhaustion requirement; must comply procedurally |
Key Cases Cited
- United States v. Griffin, 524 F.3d 71 (1st Cir. 2008) (modification of a prison sentence permitted only as authorized by statute)
- United States v. Mercado-Flores, 872 F.3d 25 (1st Cir. 2017) (sentencing court lacks jurisdiction to alter a sentence outside narrow statutory exceptions)
- United States v. Vega-Figueroa, 2025 WL 1576574 (1st Cir. 2025) (discussing categories for compassionate release under sentencing guidelines)