United States v. Greenwood, 2:11-cr-00015

Defendant Michael Greenwood pleaded guilty (Aug. 26, 2011) to possession with intent to distribute ≥50g methamphetamine and was sentenced to 188 months imprisonment plus 5 years supervised release (Nov. 10, 2011).
Greenwood moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A) due to COVID-19 risk (filed Sept. 4, 2020); projected release date December 2024.
He is 66, was diagnosed with prostate cancer in Feb. 2020 and underwent cryosurgery in July 2020; provided no medical details or prognosis to the court.
He is housed at FCI El Reno and argued prison conditions and staff infections create an inability to avoid COVID-19 exposure and warrant immediate release to home confinement.
Court applied § 3582 factors and U.S.S.G. § 1B1.13: required showing of extraordinary and compelling reasons and that defendant is not a danger to the community under 18 U.S.C. § 3142(g).
Court concluded Greenwood failed to show extraordinary and compelling reasons (receiving BOP treatment; no prognosis; preexisting conditions alone insufficient), and that he posed a danger given his drug-trafficking history and informant information; motion denied (Dec. 1, 2020).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Greenwood established "extraordinary and compelling reasons" for compassionate release under § 3582	Gov't: No — Greenwood receives BOP treatment, provided no prognosis, and preexisting conditions alone are insufficient	Greenwood: Age and prostate cancer + prison exposure risk create extraordinary and compelling reasons	Denied — court: insufficient evidence of serious, nonrecoverable condition or diminished self-care ability
Whether Greenwood is a danger to the community	Gov't: Greenwood is a danger based on informant report and lengthy drug-trafficking history	Greenwood: Release would not endanger others	Court found danger established; weighed against release
Whether general COVID-19 concerns justify release	Gov't: General COVID fears insufficient; BOP mitigation efforts relevant (Raia)	Greenwood: Prison conditions prevent effective avoidance of exposure; release necessary	Denied — general COVID risk alone does not justify compassionate release
Whether a sentence reduction would be consistent with Sentencing Commission policy (U.S.S.G. §1B1.13)	Gov't: Reduction not consistent because criteria unmet	Greenwood: Reduction consistent given health risk	Denied — statutory and policy criteria not satisfied

United States v. Raia, 954 F.3d 594 (3d Cir. 2020) (noting BOP’s COVID-19 response and holding that generalized COVID-19 fears do not independently justify compassionate release)