23-8038-cr
2d Cir.Mar 11, 2025Background
- Jasminder Singh was convicted in 2022 for bank fraud and money laundering involving a scheme to defraud American Express.
- He was sentenced to 48 months in prison by the Eastern District of New York.
- In 2023 Singh moved, pro se, for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing family circumstances, health issues, and alleged religious discrimination in prison.
- The district court denied the motion, finding no extraordinary and compelling reasons for a sentence reduction and noted that Singh presented no new circumstances affecting the sentencing factors previously considered.
- Singh appealed the denial, acting pro se, to the Second Circuit.
- The Second Circuit affirmed the district court’s order and denied Singh’s appellate motion for compassionate release.
Issues
| Issue | Singh's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether Singh showed extraordinary and compelling reasons for compassionate release | Family, medical, and religious concerns warrant sentence reduction | Singh's circumstances not extraordinary or compelling under the law | No extraordinary or compelling reasons established; motion denied |
| Whether the district court erred by not reweighing § 3553(a) factors | New circumstances require new consideration of sentencing factors | No new circumstances; prior assessment remains valid | No error; no reason to revise sentence based on prior or new facts |
| Consideration of appellate materials not before district court | New evidence should support release | Appellate review is limited to district court record | Court did not consider new materials; proper record only |
| Filing/handling of sensitive information on the docket | Not directly raised | Sensitive filings should be redacted | Docket entries sealed; no remand, but suggested review by district court |
Key Cases Cited
- United States v. Halvon, 26 F.4th 566 (2d Cir. 2022) (standard for appellate review of compassionate release denials)
- United States v. Keitt, 21 F.4th 67 (2d Cir. 2021) (either failure on extraordinary reasons or § 3553(a) factors is sufficient ground to deny compassionate release)
- United States v. Fernandez, 104 F.4th 420 (2d Cir. 2024) (standard for what constitutes extraordinary and compelling reasons for sentence reduction)
- Loria v. Gorman, 306 F.3d 1271 (2d Cir. 2002) (appeal limited to the record considered by the district court)