United States v. Jose Manuel Saldana
21-12204
11th Cir.Sep 3, 2021Background
- Jose Saldana, a federally sentenced, counsel-represented prisoner, filed an amended compassionate-release motion under the First Step Act (18 U.S.C. § 3582(c)(1)(A)).
- The district court denied the motion and made a factual finding that Saldana had already contracted and recovered from COVID-19.
- The record contained no evidence that Saldana ever tested positive; he consistently argued he faced higher risk if he were to contract COVID-19.
- The district court likely conflated Saldana’s medical history with his brother and codefendant Francisco, who had tested positive.
- The Eleventh Circuit reviews denials of Section 3582(c)(1)(A) motions for abuse of discretion and treats clearly erroneous factual findings as an abuse of discretion.
- The Eleventh Circuit granted the parties’ joint motion for summary reversal, held the district court abused its discretion, and remanded for reconsideration without deciding the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying compassionate release based on a factual finding that Saldana had contracted COVID-19 | Saldana: the court’s finding that he had already contracted COVID-19 is factually unsupported and therefore wrongful | Government: joined Saldana, arguing the district court’s factual finding was clearly erroneous | Court: The finding was clearly erroneous; denial on that basis was an abuse of discretion; summary reversal granted |
| Whether the case should be remanded for reconsideration | Saldana: remand required so the court may properly consider extraordinary-and-compelling reasons and 3553(a) factors | Government: joined remand request | Court: Remanded for the district court to reconsider; Circuit took no position on the ultimate merits |
Key Cases Cited
- Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969) (standard for summary disposition)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (abuse-of-discretion review; factual findings can be clearly erroneous)
- United States v. Puentes, 803 F.3d 597 (11th Cir. 2015) (district courts lack inherent authority to modify sentences; can act only when authorized by statute)