United States v. Fraire-Rojas
2:21-cr-00001
N.D. Tex.Jul 11, 2025Background
- Miguel Fraire-Rojas sought a sentence reduction (compassionate release) under 18 U.S.C. § 3582(c)(1)(A) after his supervised release was revoked, resulting in a 24-month prison term, consecutive to a 60-month drug conspiracy sentence.
- He is incarcerated at USP Thomson, Illinois.
- A previous motion for sentence reduction based on health concerns was denied in 2023.
- In his latest motion, Fraire-Rojas cited rehabilitation, improper sentencing enhancement, imminent deportation, and poor prison conditions (including COVID-19 effects) as grounds for release.
- The Court granted his motion to amend the information but considered only the corrected details for its analysis.
- The Court denied his motion for compassionate release.
Issues
| Issue | Fraire-Rojas's Argument | U.S. Argument | Held |
|---|---|---|---|
| Extraordinary & compelling reasons for release | Rehabilitation, prison conditions (COVID-19), deportation | Such reasons not individually sufficient | None of these reasons, alone or together, justify release |
| COVID-19 as basis for release | COVID-related hardships in prison are extraordinary | COVID-19 risks affect all inmates and are no longer extraordinary | COVID-19 is no longer a basis for compassionate release |
| Imminent deportation as basis | Imminent deportation makes continued incarceration less justified | Argument unsupported by binding authority | Imminent deportation not grounds for release |
| Application of § 3553(a) factors | His rehabilitation supports release | His criminal history and public safety risk outweigh rehabilitation | § 3553(a) factors weigh against release |
Key Cases Cited
- United States v. Raia, 954 F.3d 594 (3d Cir. 2020) (COVID-19's presence alone does not justify compassionate release)
- United States v. Chambliss, 948 F.3d 691 (5th Cir. 2020) (Compassionate release is discretionary and may be denied after weighing § 3553(a) factors)