United States v. Jeffrey Hampton, 985 F.3d 530

Jeffrey Hampton, convicted in 2009 of conspiracy to distribute cocaine and aiding and abetting possession of a firearm, was sentenced to 204 months later reduced to 180 months.
Hampton moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A); he submitted an administrative request but filed in district court before the 30-day warden response window expired; the district court waited the 30 days and then considered the motion.
The district court (not the original sentencing judge) denied Hampton’s motion in a two-line order citing “the reasons stated” in the government’s brief and concluding Hampton had not met § 3582(c)(1)(A)(i).
The government’s brief relied on U.S.S.G. § 1B1.13 commentary to argue Hampton lacked an extraordinary and compelling medical condition.
Subsequent Sixth Circuit precedent (post-dating the district court’s order) clarifies that for defendant-filed motions the Sentencing Commission’s § 1B1.13 policy statement is not binding and courts may define “extraordinary and compelling” independently.
Because the district court’s terse order did not specify whether it relied on § 1B1.13 or on its own discretionary assessment of the § 3553(a) factors, the Sixth Circuit vacated and remanded for clarification and reconsideration in light of its recent decisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by issuing a two-line denial citing the gov’t brief	Hampton: order fails to state basis; prevents meaningful appellate review	Gov’t: record and brief show why denial was proper	Vacated and remanded because the terse order didn’t permit meaningful appellate review
Whether U.S.S.G. § 1B1.13 is a mandatory gate for defendant-filed motions	Hampton: court could not rely solely on § 1B1.13	Gov’t: relied on § 1B1.13 commentary to deny release	§ 1B1.13 is not binding for defendant-filed motions; unclear reliance required remand
Whether Hampton demonstrated extraordinary and compelling reasons for release	Hampton: his circumstances merit relief	Gov’t: records do not show qualifying medical condition or other extraordinary reasons	District court previously concluded no, but appellate court did not resolve the merits and remanded for reconsideration
Whether exhaustion of administrative remedies barred the motion	Hampton: administrative request was submitted; court waited 30 days	Gov’t: could have raised exhaustion; did not raise on appeal	Appellate court declined to address exhaustion because gov’t forfeited it on appeal

United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (framework for compassionate-release review after First Step Act)
United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (Sentencing Commission policy statement § 1B1.13 is not binding on defendant-filed motions)
United States v. Alam, 960 F.3d 831 (6th Cir. 2020) (administrative exhaustion and 30-day window under § 3582(c)(1)(A))
United States v. Flowers, 963 F.3d 492 (6th Cir. 2020) (abuse-of-discretion standard for sentence-relief rulings)
United States v. White, 492 F.3d 380 (6th Cir. 2007) (abuse-of-discretion principles)
United States v. McGuire, [citation="822 F. App'x 479"] (6th Cir. 2020) (barebones orders can suffice where record or stated reasons permit meaningful review)
Chavez-Meza v. United States, 138 S. Ct. 1959 (2018) (even brief district-court orders must permit meaningful appellate review)