United States v. Guerrero, 21-20154

Jaime Guerrero was convicted in federal court of multiple offenses arising from a carjacking in which he shot and killed a victim, including §924(c) and carjacking counts; he received life imprisonment.
Guerrero, proceeding pro se, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A).
He argued the district court abused its discretion by limiting its analysis to the Sentencing Guideline policy statement (U.S.S.G. § 1B1.13) and by failing to properly weigh the 18 U.S.C. § 3553(a) factors, including recognizing that the Guidelines are advisory.
The district court denied relief, finding Guerrero had not shown extraordinary and compelling reasons for release and that the § 3553(a) factors did not support reduction even if such reasons existed.
On appeal, the Fifth Circuit reviewed the denial for abuse of discretion and affirmed, holding the district court did not err as a matter of law or clearly mis-assess the evidence and had considered the relevant factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court improperly confined its compassionate-release review to U.S.S.G. § 1B1.13	Denial was proper; Guerrero failed to show extraordinary and compelling reasons and court’s analysis was lawful	Court limited review to § 1B1.13 and thus abused its discretion	Affirmed — no legal error; denial not an abuse of discretion
Whether the district court failed to adequately consider the 18 U.S.C. § 3553(a) factors	Court properly considered § 3553(a); factors did not support release	Court did not adequately weigh § 3553(a) or note Guidelines are advisory	Affirmed — § 3553(a) factors were considered and supported denial
Whether extraordinary and compelling reasons justified release	No extraordinary and compelling reasons shown	Guerrero asserted such reasons warranted relief	Affirmed — defendant failed to demonstrate extraordinary and compelling reasons

United States v. Chambliss, 948 F.3d 691 (5th Cir. 2020) (compassionate-release denial reviewed for abuse of discretion)
United States v. Chacon, 742 F.3d 219 (5th Cir. 2014) (appellate court may affirm on any record-supported basis, including § 3553(a) analysis)