United States v. Corey Williams
987 F.3d 700
| 7th Cir. | 2021Background
- Cory Williams is serving an 18‑year federal sentence (robbery and a §924(c) firearm count) imposed in 2013.
- In 2014 he filed a §2255 motion alleging his plea was involuntary due to the judge’s participation in plea negotiations; the district court denied it and the Seventh Circuit affirmed in 2018 (no due‑process violation).
- April 2020: Williams asked his prison warden to seek compassionate release based on the trial judge’s conduct; the warden did not respond within 30 days.
- June 2020: Williams filed a pro se compassionate‑release motion in district court on the trial‑judge ground; the court appointed counsel, who amended the motion to seek release based on COVID‑19 exposure risk from Williams’s role as a chapel usher.
- The government raised an exhaustion defense, arguing Williams never presented the COVID‑19 ground to the warden; the district court bypassed exhaustion and denied the counseled motion on the merits. The Seventh Circuit affirmed, holding Williams failed to exhaust and that the pro se argument was meritless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an inmate must present the same or similar ground to the BOP to exhaust §3582(c)(1)(A) administrative remedies | Williams: his earlier warden request (trial‑judge issue) satisfied exhaustion for compassionate release generally | Government: exhaustion requires presenting the same ground (COVID risk) to the warden | Court: require issue‑specific exhaustion; inmate must present the same or similar ground to the BOP before litigating it in court |
| Whether the exhaustion requirement is mandatory and enforceable when properly invoked | Williams: district court could reach merits despite exhaustion gap | Government: exhaustion is a mandatory claim‑processing rule that must be enforced when invoked | Court: exhaustion is a mandatory, enforceable claim‑processing rule; facts show Williams failed to exhaust the COVID ground |
| Whether the district court erred in appointing counsel and then considering only the counseled amended motion (disregarding pro se filing) | Williams: district court should have considered his original pro se argument | Government/Court: appointment permits the court to consider counseled filings and disregard pro se submissions by represented litigants | Court: appointment was proper; court may limit consideration to counseled arguments |
| Merits: whether either ground (judge’s conduct or COVID risk) warranted compassionate release | Williams: trial‑judge participation and/or COVID exposure constitute extraordinary and compelling reasons | Government: neither ground warrants release; prior appellate ruling rejects trial‑judge due‑process claim; COVID risk not extraordinary given no significant medical conditions | Court: affirmed denial—trial‑judge claim is meritless (precluded by prior decision); COVID claim insufficient for release |
Key Cases Cited
- Williams v. United States, 879 F.3d 244 (7th Cir. 2018) (affirming denial of §2255 claim; judge’s Rule 11 error did not violate due process)
- Woodford v. Ngo, 548 U.S. 81 (2006) (PLRA requires proper exhaustion to give prisons opportunity to address complaints)
- Sims v. Apfel, 530 U.S. 103 (2000) (cautioning against judicially imposed issue‑exhaustion in Social Security context)
- Schillinger v. Kiley, 954 F.3d 990 (7th Cir. 2020) (PLRA exhaustion requires presenting same issue administratively)
- United States v. Patterson, 576 F.3d 431 (7th Cir. 2009) (courts may disregard pro se filings from represented litigants)
- United States v. Williams, 495 F.3d 810 (7th Cir. 2007) (represented litigants have no right to file pro se motions)