United States v. James Saunders
986 F.3d 1076
| 7th Cir. | 2021Background:
- Saunders pleaded guilty to dealing in firearms without a license and possessing a firearm as a felon after trafficking guns from Missouri to Chicago buyers, including semiautomatic weapons that could accept large-capacity magazines; he was sentenced to 60 months in January 2020.
- In June 2020 Saunders moved for compassionate release or, alternatively, transfer to home confinement under 18 U.S.C. § 3582(c)(1)(A)(i), citing chronic bronchitis, type 2 diabetes, prior blood clots and heart problems, diabetic neuropathy, hypertension, and COVID-19 risk.
- The district court and the government agreed Saunders’s medical conditions were "extraordinary and compelling."
- The district court denied release after weighing the 18 U.S.C. § 3553(a) factors, stressing the seriousness of Saunders’s firearms trafficking (and its connection to Chicago gun violence) and that Saunders had served only 19 of 60 months; it recommended BOP medical placement but did not grant release.
- Saunders also asked for transfer to home confinement; the district court declined to order it because it lacked statutory authority to change an inmate’s place of imprisonment.
- The Seventh Circuit affirmed, holding the district did not abuse its discretion in denying compassionate release and correctly concluded it could not order home confinement.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether compassionate release was required under § 3582(c)(1)(A)(i) given Saunders’s health and COVID-19 risk | Saunders: medical conditions + pandemic are extraordinary and compelling; release necessary to avoid serious COVID risk | District/Govt: even if extraordinary reasons exist, § 3553(a) factors (seriousness of offense, substantial time remaining) weigh against release | Affirmed — district did not abuse discretion; § 3553(a) factors can outweigh extraordinary and compelling reasons |
| Whether the district could order transfer to home confinement | Saunders: alternatively requested to finish sentence in home confinement | District/Govt: court lacks authority to place inmates in home confinement; only BOP/AG can effect placement (court may only recommend) | Affirmed — district properly declined to order home confinement because it lacked authority |
Key Cases Cited
- United States v. Gunn, 980 F.3d 1178 (7th Cir. 2020) (abuse-of-discretion review; §1B1.13 not binding for prisoner-filed motions)
- United States v. Chambliss, 948 F.3d 691 (5th Cir. 2020) (courts may deny release despite extraordinary reasons after considering §3553(a))
- United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (upheld denial of compassionate release based on substantial time remaining)
- United States v. Ko, 739 F.3d 558 (10th Cir. 2014) (BOP controls inmate placement; district cannot order transfer)
- Tapia v. United States, 564 U.S. 319 (2011) (district courts may recommend but not order inmate placement)