United States v. Caudle
4:16-cr-00179
N.D. OhioOct 10, 2019Background
- Defendant Brandon Caudle was sentenced on October 11, 2016 to 41 months’ imprisonment for three counts of mail fraud based on schemes he ran while incarcerated at FCI Elkton.
- PSR placed Caudle in Criminal History Category V; projected release date June 4, 2020.
- About 18 months into his term, Caudle (pro se) moved for a court order or judicial recommendation that the BOP place him in a specific halfway house (RRC) in North Carolina for at least 270 days to aid reintegration.
- The government opposed an order (arguing the court lacks authority) and suggested, at most, a broad recommendation that the BOP place Caudle in an RRC for a significant period as the BOP deems appropriate.
- Caudle renewed his request after the First Step Act, citing 18 U.S.C. § 3621(b) (proximity considerations), but later indicated he intends to release to the Northern District of Ohio.
- The court denied both the original and renewed motions, concluding the BOP—familiar with Caudle’s disciplinary history—is better positioned to decide RRC placement and declining to issue a recommendation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court can order the BOP to place Caudle in a particular halfway house | Caudle asked the court to order or recommend placement; invoked § 3621(b) and First Step Act proximity provisions | Government: court lacks authority to order BOP designations; BOP has exclusive placement authority | Court: cannot order BOP to make a specific placement; denied any order and declined recommendation |
| Whether a judicial recommendation for extended RRC placement is warranted | Caudle: extensive halfway house time would reduce recidivism; he asserts high recidivism risk and need for 270 days | Government: BOP is better positioned to assess appropriateness; case manager input and inmate record weigh against recommending placement | Court: denied recommendation based on Caudle’s disciplinary record and deference to BOP’s placement discretion |
Key Cases Cited
- Demis v. Sniezek, 558 F.3d 508 (6th Cir. 2009) (BOP may place an inmate in community confinement for no more than twelve months at end of sentence)
