United States v. Brantley, 4:12-cr-00746

Terry Brantley was convicted in 2013 of conspiracy to distribute ≥28 grams of cocaine base; original sentence 204 months, reduced to 192 months in 2020; projected release February 16, 2026.
Brantley filed a pro se compassionate release motion under 18 U.S.C. § 3582(c)(1)(A)(i), citing his hypertension (COVID-19 vulnerability) and the serious health problems of his wife (cancer and lupus) as reasons to be released to care for her.
BOP records show Brantley contracted and recovered from COVID-19 in January 2021 and refused a COVID-19 vaccine offer on April 14, 2021.
The Government opposed release, arguing Brantley failed to show "extraordinary and compelling reasons" (vaccine refusal, hypertension only a possible risk factor) and that § 3553(a) factors weigh strongly against release due to significant drug trafficking (≈4 kg crack, ≈460 g powder), firearm involvement, prior convictions, and disciplinary infractions in custody.
The Court reviewed the PSR, BOP records, applicable law and § 3553(a) factors and denied compassionate release: it found no extraordinary and compelling reason and that the § 3553(a) factors (seriousness, deterrence, public protection, lack of rehabilitation) weigh against early release.
The Court also noted it lacks authority to order BOP to place an inmate in home confinement under the CARES Act.

Issue	Brantley’s Argument	Government’s Argument	Held
Whether extraordinary and compelling reasons exist for release based on medical risk from COVID-19	Hypertension increases COVID-19 risk; prior infection and environment justify release	Brantley refused vaccine; hypertension is only a "possible" CDC risk factor and he has no terminal/functional impairment	Denied — no extraordinary and compelling reason shown
Whether spouse’s health qualifies as extraordinary and compelling family circumstance	Wife has cancer and lupus and needs Brantley as caregiver	No documentation of wife’s incapacitation; Brantley didn’t show he is sole caregiver	Denied — insufficient showing of qualifying family circumstance
Whether § 3553(a) factors support reduction	Release would allow caregiving and does not outweigh humanitarian concerns	Serious offense conduct (large-scale trafficking, armed), extensive criminal history, parole violation, and in-custody infractions show danger and need for sentence	Denied — § 3553(a) factors weigh against release
Whether the court can order BOP to grant home confinement under the CARES Act	(requested by defendant)	Court lacks statutory authority to direct BOP to place prisoner in home confinement	Denied — court cannot order BOP to grant home confinement

United States v. Edwards, 451 F. Supp. 3d 562 (W.D. Va. 2020) (defendant bears burden to establish compassionate-release relief)
United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (§ 1B1.13 is not an "applicable policy statement" for inmate-filed motions but remains persuasive guidance)
United States v. Zullo, 976 F.3d 228 (2d Cir. 2020) (district courts may consider any extraordinary and compelling reason raised by a defendant)
United States v. Kibble, 992 F.3d 326 (4th Cir. 2021) (standards for evaluating compassionate-release motions and § 3553(a) balancing)
United States v. High, 997 F.3d 181 (4th Cir. 2021) (recent Fourth Circuit decision applied in compassionate-release analysis)