United States v. Brown, 21-122-cr

Defendant Shawnta L. Brown, pro se and incarcerated, moved under 18 U.S.C. § 3582(c)(1)(A) for compassionate release, citing leukemia and risk from COVID-19.
Brown initially was denied: district court held he had not shown "extraordinary and compelling" reasons and alternatively denied relief after weighing the § 3553(a) factors.
Brown moved for reconsideration, submitting evidence of a COVID-19 outbreak at FCI Fort Dix and arguing the outbreak plus his medical condition justified relief; he also invoked Brooker as a change in law.
The district court recognized Brown’s increased COVID-19 risk and that Brooker affected the law, but again denied relief based on an individualized § 3553(a) analysis (serious drug-and-firearms conspiracy, prior felony, 248-month sentence at low end of Guidelines, need for deterrence and public safety, and medical care considerations).
The Second Circuit reviewed for abuse of discretion and affirmed, finding the district court properly considered both extraordinary-and-compelling circumstances and the § 3553(a) factors and reasonably denied relief.
The Second Circuit declined to consider an Eighth Amendment claim raised for the first time on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court abuse its discretion in denying reconsideration of the compassionate-release motion?	Brown: denial was erroneous because new outbreak evidence + his leukemia changed the analysis.	Govt/district: court considered new evidence and Brooker but reasonably denied relief under § 3553(a).	No abuse of discretion; denial affirmed.
Did Fort Dix outbreak + Brown’s leukemia constitute "extraordinary and compelling" reasons?	Brown: combined risk from leukemia and the outbreak qualifies as extraordinary and compelling.	District: acknowledged increased risk but found § 3553(a) factors nonetheless counseled against release.	Court: district could find extraordinary-and-compelling arguably met but lawfully deny relief on § 3553(a) grounds.
Did Brooker require a different outcome or mandatory reconsideration?	Brown: Brooker expanded district discretion and supports reconsideration/grant.	District: Brooker did not compel relief; it clarified discretion but § 3553(a) analysis remains required.	Brooker did not mandate relief; district correctly applied discretion and § 3553(a).
May the appellate court address Brown’s Eighth Amendment claim raised for first time on appeal?	Brown: Eighth Amendment violation due to COVID conditions at Fort Dix.	Govt: claim forfeited for failure to raise below.	Court: declined to consider it as it was raised first on appeal.

United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (district courts may consider the full slate of extraordinary and compelling reasons and have broad discretion)
United States v. Holloway, 956 F.3d 660 (2d Cir. 2020) (standard of review for discretionary sentence reductions)
United States v. Moreno, 789 F.3d 72 (2d Cir. 2015) (abuse-of-discretion review of reconsideration denials)
United States v. Borden, 564 F.3d 100 (2d Cir. 2009) (definition of abuse of discretion)
Virgin Atl. Airways, Ltd. v. Nat’l Mediation Bd., 956 F.2d 1245 (2d Cir. 1992) (grounds that justify granting reconsideration)
Analytical Surveys, Inc. v. Tonga Partners, L.P., 684 F.3d 36 (2d Cir. 2012) (reconsideration is not for relitigating old issues)
United States v. Leonard, 844 F.3d 102 (2d Cir. 2016) (district court must consider § 3553(a) when exercising reduction discretion)
United States v. Rigas, 583 F.3d 108 (2d Cir. 2009) (district court must make individualized § 3553(a) assessment)
United States v. Capanelli, 479 F.3d 163 (2d Cir. 2007) (weight given to § 3553(a) factors is committed to sentencing court’s discretion)
Greene v. United States, 13 F.3d 577 (2d Cir. 1994) (appellate courts generally will not consider issues raised first on appeal)