United States v. Carter
1:14-cr-00501
S.D.N.Y.Jul 7, 2025Background
- Leon Carter was convicted of seven bank robberies in 2013 and sentenced to 175 months in prison, classified as a career offender.
- Carter has served over 92% of his sentence (around 156 months) with credit for good behavior; his projected release was June 2026.
- Carter, now 67, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing deteriorating health due to aging.
- The First Step Act allows courts to reduce sentences if "extraordinary and compelling reasons" exist, consistent with Sentencing Commission policy and § 3553(a) factors.
- Carter demonstrated significant health decline, particularly worsening arthritis and other age-related conditions, since incarceration.
- Carter's conduct in prison, including positive behavior and overcoming substance abuse, was highlighted in support of his motion.
Issues
| Issue | Carter's Argument | Government's Argument | Held |
|---|---|---|---|
| Eligibility for Compassionate Release | Health has seriously deteriorated with age; qualifies under U.S.S.G. § 1B1.13(b)(2) | Disputes severity of deterioration; urges full sentence | Carter qualifies for extraordinary and compelling reasons |
| Appropriateness under § 3553(a) Factors | Current circumstances support reduction; sentence already substantial | Seriousness of crimes and history justify full term | Time served is sufficient considering new circumstances |
| Consideration of Pandemic Effects | Conditions harsher than anticipated due to COVID-19 | N/A | Court considers harsher conditions weigh in Carter's favor |
| Weight of Post-Incarceration Conduct | Positive prison record, improved conduct | N/A | Court finds post-sentence conduct supports release |
Key Cases Cited
- United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (clarifies courts’ discretion under First Step Act for compassionate release)
- United States v. Castillo, 2025 WL 100625 (2d Cir. Jan. 15, 2025) (not officially reported; omitting as per instructions)
- United States v. Campbell, No. 09-CR-119-24 (ARR) (omitted; not an official reporter citation)
Note: The opinion primarily references statutes and non-official citations in addition to one Second Circuit reported case (Brooker).