United States v. Cheryl Singleton
20-14366
| 11th Cir. | Oct 21, 2021Background
- Cheryl Singleton, a federal inmate serving a 150-month sentence for wire fraud, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A) after serving about one-third of her term.
- The district court denied relief, finding Singleton did not meet the statute’s criteria (including the Sentencing Commission policy statement U.S.S.G. § 1B1.13).
- Singleton argued the district court wrongly applied § 1B1.13, that it could invoke the policy-statement catch‑all (or otherwise consider her medical conditions plus rehabilitation) and that her conditions (hypertension, ulcerative colitis) made her vulnerable to COVID-19 and thus constituted extraordinary and compelling reasons.
- The government moved for summary affirmance in the Eleventh Circuit; the court reviewed eligibility de novo and denial for abuse of discretion.
- The Eleventh Circuit held its prior precedent controls: § 1B1.13 remains the applicable policy statement, district courts cannot invoke the BOP-only catch‑all, and Singleton’s common hypertension (and colitis) did not show a condition that “substantially diminishes” her ability to self-care in prison.
- Because no extraordinary and compelling reason existed, the court affirmed without reaching § 3553(a) factors and granted the government’s motion for summary disposition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of U.S.S.G. § 1B1.13 to prisoner-filed § 3582(c)(1)(A) motions | Singleton: District court should not be constrained by § 1B1.13 when prisoners move on their own behalf | Gov/District Ct.: § 1B1.13 is the applicable policy statement governing such motions | Court: § 1B1.13 applies; district courts may not grant relief unless consistent with it (Bryant controlling) |
| Use of § 1B1.13’s catch‑all (Director of BOP) or district-court expansion | Singleton: District court could treat catch‑all broadly or consider medical conditions combined with rehab | Gov/District Ct.: Catch‑all is limited to BOP determinations; district courts lack authority to expand it | Court: District courts cannot substitute their own judgment for "as determined by the Director of the BOP"; catch‑all not available to courts (Bryant) |
| Whether hypertension/colitis constitute "extraordinary and compelling" medical reasons | Singleton: Her hypertension (and colitis) increase COVID-19 risk and thus qualify as extraordinary and compelling | Gov/District Ct.: Conditions are common and do not substantially diminish her ability to self-care in prison; do not meet §1B1.13 standard | Court: Hypertension/colitis do not substantially impair self-care in prison and are not extraordinary and compelling reasons (Harris cited) |
| Whether court needed to analyze § 3553(a) despite finding no extraordinary reasons | Singleton: § 3553(a) factors favor release and should have been considered | Gov/District Ct.: All three statutory prerequisites required; absence of extraordinary reasons forecloses relief so § 3553(a) need not be reached | Court: If no extraordinary and compelling reason exists, district court need not (and should not) analyze § 3553(a); affirmed |
Key Cases Cited
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (held U.S.S.G. § 1B1.13 governs all § 3582(c)(1)(A) motions and limits district courts from using the BOP-only catch‑all)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (medical-condition standard requires showing substantial inability to self-care in prison)
- Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969) (standard for summary disposition/affirmance)
- Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (pre‑1981 Fifth Circuit decisions binding on Eleventh Circuit)
- Access Now, Inc. v. Southwest Airlines Co., 385 F.3d 1324 (11th Cir. 2004) (appellate courts may decline to consider arguments not raised below)