United States v. Harwood
1:14-cr-10042-CBK
| D.S.D. | Apr 11, 2022Background
- In September 2014 Jesse Harwood, while intoxicated, fatally stabbed his brother Dallas during a family dispute over music; Dallas died despite others' attempts to render aid and Harwood retreated to his bedroom.
- Harwood had a prior 2011 conviction for stabbing a relative and was on supervised release for that offense when he killed Dallas.
- In 2015 the Court sentenced Harwood to the statutory maximum 120 months (followed by three years supervised release) after an upward departure from a 57–71 month guideline range.
- In April 2021 Harwood submitted a Bureau of Prisons Reduction in Sentence (RIS) request based on a serious seizure disorder and alleged inadequate medical care; the warden denied it, and Harwood then moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A).
- Harwood sought release to Sisseton, SD, citing his seizure disorder (and alleged maltreatment); he also checked boxes for terminal illness and other extraordinary reasons, but provided no evidence of terminal prognosis and raised malpractice claims the Court deemed better suited for civil suit.
- The Court found exhaustion satisfied (warden denial), evaluated whether Harwood’s seizure disorder constituted an "extraordinary and compelling" reason, considered § 3553(a) factors, and denied compassionate release.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Administrative exhaustion | Govt: RIS was denied by the warden; matter ripe for judicial review | Harwood: he submitted RIS and the warden denied it | Court: exhaustion satisfied; motion ripe |
| "Extraordinary and compelling" medical reason | Govt: serious seizure disorder alone insufficient without showing it substantially diminishes ability to self-care in prison or that prison care is inadequate | Harwood: ongoing, serious seizure disorder (prior burns); alleges improper care and requests release to Sisseton | Court: Harwood’s seizure disorder acknowledged but he failed to show it substantially impairs self-care in FCI Beaumont or justify release; medical-malpractice allegations are for civil suit |
| Scope of Sentencing Commission policy statements | Govt: relies on existing policy framework but Eighth Circuit unsettled | Harwood: urges relief under compassionate-release provisions | Court: following authority allowing district courts discretion beyond pre‑First Step Act §1B1.13, but even under that discretion relief is not warranted here |
| §3553(a) factors (seriousness, deterrence, public safety) | Govt: factors weigh against release given repeated familial stabbings, failure to render aid, and need for deterrence/just punishment | Harwood: imminent release date (March 2023) and medical needs justify early release | Court: §3553(a) factors weigh strongly against early release; motion denied |
Key Cases Cited
- Guerrant v. United States, 142 S. Ct. 640 (2022) (observing Sentencing Commission lacked quorum and stopping its work)
- United States v. Rodd, 966 F.3d 740 (8th Cir. 2020) (discussing applicability of pre‑First Step Act policy statement)
- United States v. Marcussen, 15 F.4th 855 (8th Cir. 2021) (framework for district court review of compassionate‑release motions)
- United States v. Houck, 2 F.4th 1082 (8th Cir. 2021) (exhaustion requirement under §3582(c)(1)(A))
- United States v. Jones, 836 F.3d 896 (8th Cir. 2016) (defendant bears burden to show sentence reduction warranted)
- United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (district courts may identify extraordinary and compelling reasons beyond Sentencing Commission examples)
- United States v. Aruda, 993 F.3d 797 (9th Cir. 2021) (same)
- United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (same)
- United States v. Salazar‑Aleman, 741 F.3d 878 (8th Cir. 2013) (§3553(a) individualized inquiry requirement)
- United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (§3553(a) factors guide sentencing decisions)
- United States v. Contreras, 504 F. Supp. 3d 1052 (D.S.D. 2020) (district court precedent permitting broader consideration of extraordinary and compelling reasons)
- United States v. Vandebrake, 771 F. Supp. 2d 961 (N.D. Iowa 2011) (discussing gravity of offense in compassionate‑release context)