United States v. Bustamonte, 1:19-cr-00172

Angelina Bustamonte was indicted on multiple drug-related charges and pled guilty to possession of over 1,300 grams of methamphetamine, receiving a 125-month sentence.
She is currently incarcerated at FCI Tallahassee with a projected release date of July 5, 2028.
Bustamonte filed a pro se motion for early release, citing post-sentencing rehabilitation and various statutory provisions, though the court identified her primary claim as one for compassionate release under the First Step Act.
Her motion emphasized numerous rehabilitative programs completed while incarcerated but did not mention exhaustion of administrative remedies through the BOP.
The court reviewed her motion under amended U.S.S.G. § 1B1.13, which is now binding for both BOP-initiated and defendant-initiated compassionate release requests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of Remedies	Bustamonte did not exhaust administrative remedies.	(Defendant, so this issue is plaintiff by court)	Bustamonte failed to exhaust administrative remedies, warranting dismissal.
Extraordinary and Compelling Reasons	Rehabilitative efforts do not qualify as extraordinary and compelling alone.	Bustamonte's rehabilitation justifies early release.	Rehabilitation alone is insufficient to grant compassionate release.
Consistency with Sentencing Policy	Early release not consistent with § 3553(a) due to crime severity.	Conduct and rehabilitation show she won’t reoffend.	Early release inconsistent with sentencing goals in § 3553(a).
Sentence Reduction Appropriateness	Sentence should not be reduced absent extraordinary circumstances.	Sentence should be reduced due to post-conviction progress.	No extraordinary reason justifies reduction; motion denied.

United States v. Rodriguez, 424 F. Supp. 3d 674 (N.D. Cal. 2019) (discussing how courts should interpret 'extraordinary and compelling reasons' and noting Congress left this definition to the Sentencing Commission)
United States v. Aruda, 993 F.3d 797 (9th Cir. 2021) (addressing whether U.S.S.G. § 1B1.13 is binding authority on defendant-initiated compassionate release motions)