United States v. Jaime Fernando Sanchez
20-13162
| 11th Cir. | Jul 8, 2021Background
- Jaime Fernando Sanchez is serving a 168-month sentence after pleading guilty to conspiracy to commit mail and wire fraud (sentence imposed 2014).
- In June 2020 Sanchez moved for compassionate release under 18 U.S.C. § 3582(c), citing medical vulnerability to COVID-19 (former smoker, HIV-positive, muscle wasting) and an alleged unwarranted sentencing disparity.
- The district court denied relief, reasoning it was bound by the extraordinary-and-compelling reasons enumerated in USSG § 1B1.13 and concluding Sanchez’s conditions did not meet that standard.
- The district court also rejected the sentencing-disparity claim, noting comparator differences (different enhancements, government-recommended downward variance) and that Sanchez breached his plea (continued criminal activity, false implication of others, destroyed evidence).
- The Eleventh Circuit reviewed for abuse of discretion and affirmed the denial: Sanchez’s medical conditions did not establish inability to self-care or increased COVID-19 vulnerability sufficient for release, and sentencing-disparity arguments were either unwarranted or not cognizable under the policy statement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sanchez’s medical conditions qualify as "extraordinary and compelling" for compassionate release | Sanchez: former smoker, HIV-positive, muscle wasting make him especially vulnerable to COVID-19 and unable to self-care | Gov/District: Conditions are stable/no evidence of inability to self-care; policy statement controls and he does not meet its criteria | Denied — conditions do not show diminished ability to self-care or nonrecoverable condition sufficient under USSG §1B1.13 |
| Whether an alleged unwarranted sentencing disparity supports compassionate release | Sanchez: his sentence is harsher than comparators and thus is an extraordinary and compelling reason | Gov/District: Comparators are not similarly situated (different enhancements, variances); sentencing disparity is not an "extraordinary and compelling" reason under the policy statement | Denied — disparity unjustified on the facts, and sentencing disparities are not cognizable under USSG §1B1.13 absent BOP approval (per Bryant) |
Key Cases Cited
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (abuse-of-discretion standard reviewing §3582(c) denials)
- United States v. Khan, 794 F.3d 1288 (11th Cir. 2015) (definition of abuse of discretion and review scope)
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (district courts limited to the "extraordinary and compelling" reasons in USSG §1B1.13 unless BOP approves other reasons)