United States v. Clay C. Keys
20-12318
| 11th Cir. | Jul 16, 2021Background:
- Clay Keys pleaded guilty in 2013 to receiving/distributing child pornography and being a felon in possession of ammunition; sentencing range calculated at 262–327 months but reduced to 180 months for substantial assistance, followed by lifetime supervised release.
- Keys filed pro se compassionate-release motions (July 2019 and May 2020) under 18 U.S.C. § 3582(c)(1)(A), citing multiple chronic medical conditions and alleged inadequate BOP medical care; he later emphasized COVID-19 risk.
- Keys argued he could self-care and would not be dangerous if released because he’d face stringent supervised-release conditions and had only downloaded (not produced/distributed) child pornography.
- The district court denied both motions: it found Keys’s medical conditions did not qualify as "extraordinary and compelling," and concluded he remained a danger to the community given the nature of his offenses, admissions of sexual attraction to children, and criminal history.
- The district court also treated Keys’s claims of inadequate medical care and BOP deliberate indifference as matters for civil litigation, not as bases for sentence reduction.
- Keys appealed; the Eleventh Circuit reviewed the denial for abuse of discretion and affirmed.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Keys’s medical conditions/COVID risk constitute "extraordinary and compelling reasons" for release | Keys: chronic illnesses and COVID vulnerability justify release | Gov.: conditions not terminal nor do they substantially diminish Keys’s ability to self-care | Court: No; Keys did not show terminal illness or substantially diminished self-care, so no extraordinary and compelling reason |
| Whether Keys would be a danger to the community if released | Keys: supervised-release conditions and time served mitigate risk; offense was only downloading, no contact with children | Gov.: Keys’s offenses involved minors; he admitted sexual attraction to children and has prior convictions and probation violations | Court: Yes dangerous; district court reasonably relied on offense nature, admissions, and criminal history to deny release |
| Whether alleged inadequate medical care / BOP deliberate indifference justify compassionate release | Keys: inadequate care and poor COVID mitigation amount to Eighth Amendment/deliberate indifference warranting release | Gov.: such claims are civil matters and do not justify sentence reduction under § 3582(c)(1)(A) | Court: These claims do not justify early release and are more properly addressed in civil litigation |
Key Cases Cited
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (compassionate-release denials reviewed for abuse of discretion)
- United States v. Puentes, 803 F.3d 597 (11th Cir. 2015) (district court may modify a sentence only when authorized by statute)
- United States v. Khan, 794 F.3d 1288 (11th Cir. 2015) (defining abuse-of-discretion review standards)
- Timson v. Sampson, 518 F.3d 870 (11th Cir. 2008) (courts construe pro se filings liberally)