United States v. Hilton Jr.
3:13-cr-00030
| M.D. Fla. | Jan 30, 2025Background
- Ervin Hilton, Jr., a 64-year-old inmate at Orlando RRM, is serving a 180-month sentence for cocaine distribution and being a felon in possession of a firearm.
- Hilton filed a pro se motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing medical conditions, family circumstances, his age/length of sentence, and a prior assault while incarcerated.
- The United States opposed the motion, and Hilton replied.
- The court reviewed the motion using the criteria in § 3582(c)(1)(A), the Sentencing Commission's policy statements, and the § 3553(a) sentencing factors.
- The decision was made after a full review of the merits, medical records, and Hilton's criminal history.
Issues
| Issue | Hilton's Argument | Government's Argument | Held |
|---|---|---|---|
| Medical conditions justify release | BOP cannot properly care for Hilton’s health needs | BOP provides adequate care; conditions not extraordinary/compelling | Denied - Records show care is adequate, conditions not severe enough |
| Family circumstances (caregiver) | Brother and sister-in-law need his help | Insufficient evidence of incapacitation or that Hilton is only caregiver | Denied - Not enough evidence for family-based release |
| Age/portion of sentence served | Advanced age, served over half his term | Not 65, no serious deterioration in health | Denied - Does not meet criteria for age-based release |
| Assault in prison/ BOP policy | Assaulted by inmate in 2018, challenges BOP policies | Assault not committed by staff, no serious injury; not proper avenue for policy complaints | Denied - Not applicable for reduction under cited grounds |
Key Cases Cited
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (Sentencing Commission’s policy statement defines "extraordinary and compelling reasons" for compassionate release)
- United States v. Green, 764 F.3d 1352 (11th Cir. 2014) (movant bears burden to show entitlement to compassionate release)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (district court's decision to grant or deny compassionate release is discretionary)
- United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021) (three mandatory conditions for sentence reduction under § 3582(c)(1)(A))