United States v. David Newton
996 F.3d 485
| 7th Cir. | 2021Background
- David Newton, serving a 220‑month federal sentence for bank robbery and a related firearms offense, moved for compassionate release in May 2020 after ~12 years in custody.
- He argued COVID‑19 put him at elevated risk because of asthma, prolonged corticosteroid use (which he said weakened his immune system), and hypertension.
- Newton submitted medical records, letters about conditions at FCI Seagoville, a detailed plan to live with family in Chicago, and travel arrangements. He contracted COVID‑19 in July 2020; BOP records said the infection had “resolved” but noted ongoing cough, headaches, and asthma flare‑ups.
- The district court denied release in a short order: noting CDC guidance that Newton’s conditions only “might” increase risk, citing Newton’s prior recovery, and observing few active cases at FCI Seagoville.
- The Seventh Circuit vacated and remanded, concluding the district court failed to show it adequately considered Newton’s principal, individualized arguments (particularly the cumulative effect of comorbidities and the proposed release plan) and relied on unsupported medical inference; a dissent argued the district court’s summary order was sufficient and Newton had not proven a combined‑conditions theory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether U.S.S.G. §1B1.13 limits district courts deciding inmate‑filed compassionate release motions | Newton: §1B1.13 should not constrain the court; inmate motions are authorized by statute after exhaustion | Gov: §1B1.13 and BOP policy narrow what counts as "extraordinary and compelling" | Court: §1B1.13 does not bind courts deciding inmate‑filed motions; but district court did not explicitly rely on it here, so no clear error on that ground |
| Whether Newton’s medical conditions constitute "extraordinary and compelling reasons" individually or cumulatively | Newton: asthma, prolonged steroid use, and hypertension together materially increase COVID‑19 risk; medical records support cumulative risk | Gov: CDC lists these as conditions that only "might" increase risk; Newton’s prior recovery undermines claim | Court: District court erred by treating CDC’s “might” as dispositive and failing to assess cumulative effect; remand for focused consideration |
| What weight prior COVID‑19 infection should receive | Newton: prior infection with lingering symptoms does not show immunity or negligible future risk | Gov: Prior recovery suggests lower risk of severe reinfection | Court: District court made unexplained inferences from prior infection and overlooked medical records documenting continuing symptoms; needs clearer fact‑based assessment |
| Proper comparison of prison risk to post‑release risk and adequacy of release plan | Newton: detailed plan shows he would live with few people and could materially reduce risk post‑release | Gov: Prison’s low active case count meant risk in custody was not higher than community risk | Court: District court used a flawed comparison (vague "general population") and failed to consider Newton’s individualized release plan; remand required |
Key Cases Cited
- United States v. Gunn, 980 F.3d 1178 (7th Cir. 2020) (exhaustion is an affirmative defense and movant bears burden to show extraordinary and compelling reasons)
- United States v. Joiner, 988 F.3d 993 (7th Cir. 2021) (district court need not address generalized arguments unsupported by individualized evidence)
- United States v. Rosales, 813 F.3d 634 (7th Cir. 2016) (district court must give reasonable assurance it considered principal arguments)
- United States v. Castaldi, 743 F.3d 589 (7th Cir. 2014) (appellate review requires district courts to make their reasoning clear)
- James v. Eli, 889 F.3d 320 (7th Cir. 2018) (courts should consider individualized evidence presented by petitioners)