United States v. Camberos-Villapuda, 4:13-cr-40104

Luciano Camberos-Villapuda was convicted in 2015 of conspiracy to distribute 500 grams or more of methamphetamine and sentenced to life imprisonment, based on two prior felony drug convictions that triggered a mandatory life sentence under 21 U.S.C. § 841(b)(1)(A).
Following the passage of the First Step Act (FSA), Camberos-Villapuda, through counsel, filed for compassionate release, arguing that subsequent amendments to federal law would result in a much lower sentence if sentenced today.
The 2018 FSA and subsequent Sentencing Commission amendments allow prisoners to seek compassionate release based on “extraordinary and compelling reasons,” including gross sentencing disparity due to nonretroactive changes in law.
Camberos-Villapuda contended that, due to changes in statutory definitions, his prior convictions would not today trigger a mandatory life sentence, and thus a gross disparity exists.
The government opposed the motion but did not contest administrative exhaustion, waiving this procedural issue.
The court ultimately denied the motion, finding no gross disparity in the guideline sentencing range and concluding that the § 3553(a) sentencing factors weighed against release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Camberos-Villapuda qualifies for	No extraordinary/compelling reason; laws unchanged	Nonretroactive law changes create gross disparity	No qualifying extraordinary/compelling reason found
compassionate release under FSA	guideline life term remains appropriate	between current sentence and modern sentencing	motion denied
Administrative exhaustion of BOP remedies	Did not challenge exhaustion, thereby waiving issue	Filed with warden after court motion filed	Waiver applies; court considered motion on merits
Applicability of intervening change in law	Changes do not reduce guideline range—life still	Sentence today would not be mandatory life,	Even with change, guideline range is still life;
to sentence disparity analysis	applies	especially as 1989 conviction no longer qualifies	no gross disparity
Application of § 3553(a) sentencing factors	Seriousness, recidivism, and public safety support	No specific rebuttal beyond claimed disparity	Factors weigh against reduction; release denied
	continued life sentence

United States v. Jones, 836 F.3d 896 (8th Cir. 2016) (burden on defendant to show entitlement to sentence reduction under § 3582)
United States v. Houck, 2 F.4th 1082 (8th Cir. 2021) (procedural requirements for § 3582(c) motions are mandatory claim-processing rules, not jurisdictional)
United States v. Saladino, 7 F.4th 120 (2d Cir. 2021) (§ 3582(c) exhaustion can be waived by the government)