United States v. Ian Owens, 996 F.3d 755

Background:

In 2004 Ian Owens was convicted of multiple bank robberies and five counts under 18 U.S.C. § 924(c); because § 924(c) required stacking of mandatory minimums then, he received an effective 115‑year sentence (trial produced additional stacked § 924(c) terms).
Owens’s co‑defendants who pleaded guilty received substantially lower sentences; the government had offered plea deals Owens rejected.
The First Step Act § 403 amended § 924(c) to limit § 924(c) stacking for defendants without a prior final § 924(c) conviction; if sentenced today Owens would face a much shorter mandatory term (the court notes a 300‑month aggregate for his five § 924(c) counts).
Owens moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing the sentencing disparity caused by the First Step Act, his rehabilitation, and the fact his lengthy term flowed from exercising his right to trial were together ‘‘extraordinary and compelling reasons.’’
The district court denied relief solely because Congress did not make § 403 fully retroactive and thus (in the court’s view) the First Step Act disparity could not be treated as an extraordinary and compelling reason; it did not consider Owens’s rehabilitation or the § 3553(a) factors.
The Sixth Circuit reversed and remanded, holding a district court may consider the First Step Act–created disparity together with other individualized factors (e.g., rehabilitation, punishment for going to trial) when assessing extraordinary and compelling reasons, and directed the district court to reconsider Owens’s motion and § 3553(a) factors.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing disparity caused by the First Step Act’s amendment to § 924(c) alone constitutes an "extraordinary and compelling reason" for compassionate release	Owens: the disparity between his current sentence and the sentence he would receive under the First Step Act is extraordinary and compelling	Government: Congress declined to make § 403 fully retroactive; allowing relief would circumvent congressional intent	Court: Disparity alone is not necessarily dispositive, but district courts may consider the disparity in combination with other individualized factors when assessing extraordinary and compelling reasons; remand to reconsider
Whether the district court abused its discretion by denying relief without considering Owens’s rehabilitative record, his trial choice, and the § 3553(a) factors	Owens: rehabilitation and the fact his sentence resulted from exercising trial rights, together with the First Step Act disparity, warrant relief	District court/Government: relied on nonretroactivity and declined to consider the other factors	Court: District court abused its discretion by failing to consider Owens’s other arguments and the § 3553(a) factors; remand for individualized consideration

Key Cases Cited

United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (standard of review and § 3582(c)(1)(A) requirements)
United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (court must find extraordinary and compelling reasons)
United States v. Flowers, 963 F.3d 492 (6th Cir. 2020) (de novo review of statutory interpretation)
United States v. Tomes, 990 F.3d 500 (6th Cir. 2021) (First Step Act changes alone failed to justify release in that posture)
United States v. Wills, 991 F.3d 720 (6th Cir. 2021) (denial affirmed where only First Step Act disparity was argued)
United States v. McGee, 992 F.3d 1035 (10th Cir. 2021) (First Step Act changes may be considered with other factors; remand for individualized review)
United States v. Maumau, 993 F.3d 821 (10th Cir. 2021) (affirming release based on combined factors including First Step Act disparity)
United States v. Richardson, 948 F.3d 733 (6th Cir.) (interpreting First Step Act applicability)
United States v. Henry, 983 F.3d 214 (6th Cir. 2020) (First Step Act applicability to resentencings)
United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (compassionate release as a safety valve under § 3582)
Booker v. United States, 543 U.S. 220 (2005) (Sentencing Guidelines are advisory)