United States v. Cruz-Rivera, 137 F.4th 25

Carlos Cruz-Rivera was convicted in 2016 of three carjacking counts, one weapons count, and three § 924(c) firearm counts, resulting in a total sentence of 872 months (nearly 73 years), largely due to 'stacked' mandatory minimum sentences under then-existing § 924(c).
In 2018, the First Step Act (FSA) amended § 924(c) to reduce the severity of mandatory minimum sentencing for multiple convictions, but the change was not retroactive.
Cruz filed a motion under 18 U.S.C. § 3582(c)(1)(A) (compassionate release) seeking a sentence reduction, arguing that the nonretroactive FSA changes and the extreme sentence disparity create 'extraordinary and compelling reasons' for relief.
The district court initially denied the motion, then again after a remand in light of United States v. Ruvalcaba, 26 F.4th 14 (1st Cir. 2022), issuing only brief text orders and not clarifying its reasoning.
On appeal, Cruz challenged the district court's understanding of its discretion under Ruvalcaba, particularly whether the sentencing disparity and his age could together constitute an 'extraordinary and compelling' reason for relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether nonretroactive changes to § 924(c) via the FSA, combined with Cruz's age and sentence disparity, can constitute 'extraordinary and compelling reasons' for a sentence reduction	Cruz: Yes; unique individual circumstances and extreme disparity justify relief	USA: No; law does not permit retroactive application, and statutory factors are narrowly defined	The district court may consider these factors, but must clarify and apply Ruvalcaba's holding
Whether the district court denied the motion based solely on improper legal grounds or failed to consider § 3553(a) factors	Cruz: District court did not explain ruling or consider all required factors	USA: District court's reasoning can be inferred from the record; discretionary denial justified	Remand required; appellate court could not discern district court's reasoning
Scope of district court discretion under Ruvalcaba	Cruz: District court misunderstood its authority to grant relief based on prospectively applicable law	USA: District court understood Ruvalcaba but Cruz did not present required 'other factors'	Remand for clarification on individualized assessment as mandated by Ruvalcaba
Need for recusal of district judge on remand	Cruz: Prior dismissal indicates partiality	USA: No partiality shown	No recusal; record did not support bias or partiality

Deal v. United States, 508 U.S. 129 (1993) (interpreted § 924(c) 'stacking' for enhanced mandatory minimums)
United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (severity of § 924(c) sentences and post-FSA disparities can constitute extraordinary and compelling reasons)
United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (district courts' authority to consider defendant-initiated compassionate release motions)
United States v. Cruz-Rivera, 904 F.3d 63 (1st Cir. 2018) (previous appeal affirming original sentence)
United States v. Saccoccia, 10 F.4th 1 (1st Cir. 2021) (standards for review of sentence reduction motions)
United States v. Texeira-Nieves, 23 F.4th 48 (1st Cir. 2022) (district court's requirement to state grounds for ruling on sentence reduction motions)
United States v. Gilman, 478 F.3d 440 (1st Cir. 2007) (remand required when appellate review is frustrated by lack of district court findings)
United States v. Feliz, 453 F.3d 33 (1st Cir. 2006) (need for clear district court reasoning to enable appellate review)