United States v. Ednecdia Sutina Johnson
20-14098
| 11th Cir. | Jun 11, 2021Background:
- Ednecdia Johnson, a federal prisoner proceeding pro se, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A) as amended by the First Step Act; the district court denied relief.
- Johnson argued her hypertension and past bronchitis, in combination with COVID-19 risk, constituted "extraordinary and compelling" reasons for a sentence reduction.
- Medical records showed bronchitis resolved over three years earlier and hypertension is controlled with medication.
- The district court applied the Sentencing Commission policy statement (U.S.S.G. § 1B1.13) and concluded Johnson’s conditions, alone or with COVID-19, did not meet the extraordinary-and-compelling standard.
- The government moved for summary affirmance in the Eleventh Circuit; the panel reviewed eligibility de novo and denial for abuse of discretion.
- The Eleventh Circuit granted summary affirmance and affirmed, holding Johnson’s medical situation (and the mere existence of COVID-19) did not justify compassionate release.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson’s medical conditions + COVID-19 are "extraordinary and compelling" reasons under § 3582 | Hypertension and prior bronchitis, combined with COVID-19 risk, warrant release | Conditions are not serious or impairing enough; COVID-19 risk alone insufficient | Denied — conditions not extraordinary and compelling |
| Whether the mere existence/spread of COVID-19 in prisons can justify release | COVID-19 exposure risk + medical history justifies release | Mere possibility of COVID-19 spread cannot independently justify compassionate release | Denied — COVID-19 alone is insufficient (Raia principle) |
| Appropriate standard of review and disposition (summary affirmance) | Sought reversal of district court denial | Government moved for summary affirmance | Granted summary affirmance; reviewed eligibility de novo and denial for abuse of discretion; no error found |
Key Cases Cited
- Tannenbaum v. United States, 148 F.3d 1262 (11th Cir. 1998) (pro se pleadings are liberally construed)
- Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969) (summary disposition appropriate when one party’s position is clearly right or appeal frivolous)
- Raia v. United States, 954 F.3d 594 (3d Cir. 2020) (mere existence of COVID-19 in society and possible spread in prisons cannot alone justify compassionate release)
- Harris v. United States, 989 F.3d 908 (11th Cir. 2021) (abuse-of-discretion review and limits on reversal standard)
- Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (Eleventh Circuit binds pre‑October 1981 Fifth Circuit decisions)