United States v. Darryl Vaughn, 21-13748

Darryl Vaughn, a federal prisoner and career offender, moved pro se for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing COVID-19 risks from diabetes, hypertension, high cholesterol, heart and kidney problems.
Vaughn argued the First Step Act would reduce his mandatory minimum to 25 years (instead of his life sentence), and pointed to rehabilitation, education, family support, and a mental disability as reasons for release.
The district court denied relief, concluding that even if Vaughn were eligible, the § 3553(a) sentencing factors (particularly his extensive criminal history and career-offender status) weighed against a reduced sentence.
The district court also stated that, under circuit law, the First Step Act’s nonretroactive change alone did not constitute an "extraordinary and compelling" reason for release.
Vaughn’s record included reoffending within two years after a reduced sentence, accountability for 27.6 kg of cocaine, and multiple prior convictions (cocaine offenses, grand theft, burglaries, assaults, battery, resisting arrest).
The Eleventh Circuit affirmed, holding the district court did not abuse its discretion in denying compassionate release because § 3553(a) factors justified continuation of the life sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying compassionate release	Vaughn: medical vulnerability, rehabilitation, and changed mandatory minimum justify release	Govt: § 3553(a) factors and Vaughn’s serious criminal history weigh against release	No abuse of discretion; denial affirmed
Whether the First Step Act’s change to mandatory minimums alone is an "extraordinary and compelling" reason	Vaughn: nonretroactive change effectively reduces his applicable mandatory minimum to 25 years and is extraordinary	Circuit law: a nonretroactive change alone does not qualify as extraordinary and compelling	District court correctly treated it as insufficient under circuit precedent (and need not resolve further)
Whether the court must resolve extraordinary-and-compelling reasons before applying § 3553(a)	Vaughn: identified extraordinary reasons (health, changes in law, rehabilitation)	Govt: even if extraordinary reasons exist, § 3553(a) factors can independently bar relief	Court: district court not required to resolve extraordinary-and-compelling if § 3553(a) would independently deny relief

United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (abuse-of-discretion standard for reviewing compassionate-release denials)
Cordoba v. DIRECTV, LLC, 942 F.3d 1259 (11th Cir. 2019) (framework for identifying abuse of discretion)
United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021) (district court may deny compassionate release based on § 3553(a) without deciding extraordinary-and-compelling issue)