United States v. Eric Johnson
20-3436
| 3rd Cir. | Jun 23, 2021Background
- In July 2013, Eric Johnson pleaded guilty to conspiracy to distribute crack cocaine and was sentenced to 188 months' imprisonment; projected release December 2027.
- In August 2020 Johnson requested compassionate release from the warden at FCI Petersburg Low; the warden denied the request and Johnson, through counsel, moved in district court.
- Johnson is 50 and has latent tuberculosis and stage 2 chronic kidney disease; he previously contracted COVID-19 while incarcerated without apparent deterioration, and the facility had largely contained the outbreak.
- The District Court denied compassionate release on November 5, 2020, concluding either that Johnson’s health/age did not amount to extraordinary and compelling reasons or, alternatively, that the § 3553(a) factors weighed strongly against release.
- The District Court emphasized Johnson’s status as a career offender with repeated drug convictions, parole violations, illegal weapon possession, and a history of violence when assessing the need for the original sentence.
- Johnson appealed; the Third Circuit reviewed the denial for abuse of discretion and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Johnson’s age and health conditions qualify as "extraordinary and compelling reasons" under 18 U.S.C. § 3582(c)(1)(A) | Johnson: latent TB and chronic kidney disease increase COVID-19 risk and thus justify release | District Court/Gov: Johnson already had COVID-19 without deterioration and the institution controlled spread, undercutting extraordinary-and-compelling claim | Third Circuit: No abuse of discretion in District Court’s conclusion (not persuaded extraordinary and compelling reasons shown) |
| Whether the § 3553(a) factors support compassionate release | Johnson: served ~half his sentence, good institutional conduct, employment, education, low recidivism risk, deterrence achieved | District Court/Gov: Johnson is a career offender with repeated offenses and violence; original sentence necessary to protect public and achieve deterrence/rehabilitation | Third Circuit: § 3553(a) factors weigh strongly against release; denial affirmed |
| Standard of review for denying compassionate release | Johnson: challenges district court’s discretion | District Court/Gov: decision reviewed for abuse of discretion | Third Circuit: reviews for abuse of discretion; will not reverse absent a "definite and firm conviction" of error |
Key Cases Cited
- United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (abuse-of-discretion standard for reviewing compassionate-release denials)
- Oddi v. Ford Motor Co., 234 F.3d 136 (3d Cir. 2000) ("definite and firm conviction" standard for overturning discretionary decisions)