United States v. James Pizer
21-6477
| 4th Cir. | Sep 17, 2021Background
- James Nathan Pizer appealed the district court's denial of his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i) during the COVID-19 pandemic.
- Pizer argued his medical conditions and COVID-19 exposure risk at his facility constituted "extraordinary and compelling" reasons for release.
- The district court considered the statutory three-step framework (extraordinary and compelling reasons; consistency with Sentencing Commission policy statements; and the 18 U.S.C. § 3553(a) factors) and denied relief.
- The district court (the same judge who sentenced Pizer) determined that the § 3553(a) factors—seriousness of the offense, criminal history, deterrence, and protection of the public—weighed against release, even if health risks were present.
- Pizer appealed, claiming the court abused its discretion in both finding his conditions insufficient as extraordinary and compelling and in its weighing of the § 3553(a) factors.
- The Fourth Circuit affirmed, holding the district court did not abuse its discretion and dispensing with oral argument.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pizer's medical conditions/COVID-19 risk constitute "extraordinary and compelling" reasons to reduce sentence | Pizer: his health conditions and pandemic exposure create an extraordinary and compelling reason for release | Government: factual and legal showing insufficient to meet that standard | Court did not grant release; even if heightened risk existed, § 3553(a) factors foreclosed relief |
| Whether the district court abused its discretion in applying the § 3553(a) factors | Pizer: the § 3553(a) factors support release when balanced with his health risks | Government: the seriousness of the offense, criminal history, deterrence, and public protection weigh against release | Court: no abuse of discretion—§ 3553(a) factors weighed against compassionate release |
Key Cases Cited
- United States v. High, 997 F.3d 181 (4th Cir. 2021) (sets out three-step framework for compassionate-release review)
- United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (no applicable Sentencing Commission policy statement for defendant-filed compassionate-release motions)
- United States v. Dillard, 891 F.3d 151 (4th Cir. 2018) (standard for abuse of discretion)
- United States v. Feiling, 453 F. Supp. 3d 832 (E.D. Va. 2020) (explaining extraordinary-and-compelling showing in COVID-19 context requires both particularized susceptibility and particularized risk of contracting disease at facility)