United States v. Jerry Fruit, 21-1272

Jerry Fruit pleaded guilty in 2018 to conspiracy to distribute heroin and cocaine and possession with intent to distribute; sentenced to a mandatory 120-month federal term, imposed consecutively to another federal sentence.
In October 2020 Fruit moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing COVID-19 risk from obesity, coronary disease/high cholesterol, and angina.
The District Court denied release, finding Fruit’s medical conditions were being treated, infection risk at USP-Lewisburg Camp was low at the time, and Fruit had a recidivist criminal history raising public-safety concerns under the § 3553(a) factors.
Fruit moved for reconsideration, alleging weight gain from COVID restrictions and an outbreak at the camp; the District Court again denied relief, noting infected inmates were isolated and reiterating the danger posed by Fruit’s criminal history.
The Third Circuit reviewed for abuse of discretion, considered the timeliness of Fruit’s filings under the prison-mailbox rule, and summarily affirmed the District Court, concluding that even assuming extraordinary circumstances, the § 3553(a) factors weighed strongly against release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fruit showed "extraordinary and compelling" reasons for compassionate release due to COVID-19 and his medical conditions	Fruit: medical vulnerability (obesity, coronary disease, angina) and a prison COVID outbreak justify release	Gov/District Court: medical conditions are being treated/managed; infections were isolated and largely mild; no extraordinary-and-compelling showing	Denied — District Court found no extraordinary-and-compelling basis; Circuit affirmed (noting that even if such reasons existed, § 3553(a) factors control)
Whether the § 3553(a) factors support compassionate release	Fruit: medical vulnerability outweighs recidivism concerns	Gov/District Court: Fruit's recidivist criminal history and need to protect public weigh heavily against release	Denied — § 3553(a) factors weighed strongly against relief; Court discerned no abuse of discretion
Timeliness of post-judgment filings (reconsideration and appeal) under the prison-mailbox rule	Fruit: motion for reconsideration was deposited in outgoing prison mail on Dec 7, 2020; appeal timely	Gov: initial docket suggests later filing dates; timeliness thus in question	Held timely — Court accepted Fruit’s declaration, applied mailbox rule, and treated the reconsideration motion and subsequent appeal as timely

United States v. Garner, 961 F.3d 264 (3d Cir. 2020) (court previously affirmed Fruit's conviction and sentence)
United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (abuse-of-discretion standard for reviewing compassionate-release denials)
Oddi v. Ford Motor Co., 234 F.3d 136 (3d Cir. 2000) (statement of appellate standard: no disturbance absent clear error of judgment)
Gomez-Gomez, 643 F.3d 463 (6th Cir. 2011) (discussing the mailbox rule and timeliness of filings)