United States v. Joel Wright, 46 F.4th 938

Joel Alexander Wright pleaded guilty in 2016 to attempted enticement of a minor (18 U.S.C. § 2422(b)) and was sentenced to 188 months’ imprisonment plus lifetime supervised release; projected release in 2029.
In September 2020 Wright moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), seeking time served (or alternatively home confinement) based on serious medical disabilities and COVID-19 risks and disrupted access to disability-related care in prison.
The district court declined to rule whether Wright’s medical conditions were “extraordinary and compelling,” found (erroneously under Aruda) that U.S.S.G. § 1B1.13 showed Wright remained dangerous, and alternatively denied relief under the § 3553(a) factors; the court did not separately analyze the home-confinement request.
On appeal Wright argued the court abused its discretion by treating § 1B1.13 as binding (contrary to Aruda) and by failing to consider his home-confinement alternative; he had not developed specific arguments or evidence for home confinement below.
The Ninth Circuit affirmed: it held the § 1B1.13 error was harmless because the district court’s independent § 3553(a) analysis supported denial, and that the court adequately dealt with the unsupported home-confinement request.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by treating U.S.S.G. § 1B1.13 as a binding constraint when denying compassionate release	Wright: the court improperly relied on § 1B1.13 (Aruda says it is not binding for defendant-filed motions)	Government: even if reliance on § 1B1.13 was error, the § 3553(a) factors independently justify denial	The court erred in applying § 1B1.13 as binding, but the error was harmless because the § 3553(a) analysis independently supported denial
Whether the district court abused its discretion by failing to address Wright’s alternative request for home confinement	Wright: court should have considered home confinement as an alternative that would address medical concerns while preserving punishment	Government: Wright presented no developed arguments or evidence for home confinement; home confinement requires a sentence reduction and BOP controls place of confinement	No abuse — the district court adequately explained denial; it was not required to address an unsupported, passing request for home confinement

United States v. Aruda, 993 F.3d 797 (9th Cir. 2021) (Sentencing Guideline § 1B1.13 is not an applicable, binding policy statement for defendant-filed compassionate-release motions)
United States v. Keller, 2 F.4th 1278 (9th Cir. 2021) (a court properly denying compassionate release need not evaluate every sequential step when one ground suffices)
United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (First Step Act permits defendants to file compassionate-release motions directly; district courts exercise individualized discretion)
United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (historical BOP gatekeeping and rationale for First Step Act reforms)
United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (three-part framework for compassionate-release review: extraordinary and compelling reasons, consistency with policy statements, and § 3553(a) factors)
Chavez-Meza v. United States, 138 S. Ct. 1959 (2018) (appellate review requires sufficient judicial explanation that the court considered parties’ arguments)
United States v. Trujillo, 713 F.3d 1003 (9th Cir. 2013) (district court must address specific, nonfrivolous arguments tied to § 3553(a) factors)