United States v. Labra
4:15-cr-00107-MAC-KPJ
E.D. Tex.Aug 2, 2021Background
- Labra pleaded guilty in 2016 to conspiracy to possess with intent to distribute methamphetamine and was sentenced to 135 months; projected release date December 3, 2024.
- He is incarcerated at FCI Bastrop and filed a pro se motion for compassionate release asserting medical conditions (Type 2 diabetes, obesity, hyperlipidemia, history of hypertension) and a desire to care for his elderly mother.
- Labra did not produce evidence that he submitted a compassionate-release request to his facility warden; BOP records show no such request.
- Medical records show his conditions are managed (Care Level 2); he is ambulatory, employed in food service, and fully vaccinated for COVID-19.
- The court found his mother is not shown to be incapacitated and that other family members could assist; Labra also cited rehabilitation and COVID-related risks.
- Court denied the motion: Labra failed administrative-exhaustion requirement, did not show “extraordinary and compelling” reasons, and §3553(a) factors weigh against release given offense seriousness and criminal history.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Administrative exhaustion | Labra contends he sought home confinement and exhausted remedies | Gov’t and BOP: no record of a compassionate-release request to the warden | Motion denied for failure to show required BOP request/exhaustion |
| Extraordinary & compelling — medical/COVID risk | Labra: diabetes, obesity, hypertension, hyperlipidemia increase COVID risk and justify release | Gov’t: conditions are common, controlled, managed by BOP; Labra is vaccinated; no terminal or incapacitating illness | Court: conditions are not extraordinary and compelling; vaccination and medical management negate release ground |
| Extraordinary & compelling — family caregiver | Labra: needs to be released to care for 92‑year‑old mother | Gov’t: mother not shown incapacitated; other relatives available; no documentation | Court: family-caregiver argument fails; not sole caregiver and no disabling incapacity proven |
| Discretion / §3553(a) factors | Labra emphasized rehabilitation and family needs | Gov’t: offense severity, criminal history, in‑custody discipline, short portion of sentence served counsels denial | Court: even if eligible, §3553(a) considerations and public safety weigh against release; motion denied |
Key Cases Cited
- United States v. Franco, 973 F.3d 465 (5th Cir. 2020) (exhaustion requirement for §3582(c)(1)(A) is mandatory)
- United States v. Alam, 960 F.3d 831 (6th Cir. 2020) (statutory exhaustion is mandatory and must be enforced)
- United States v. Raia, 954 F.3d 594 (3d Cir. 2020) (presence of COVID-19 in prisons alone does not justify compassionate release)
- United States v. Shkambi, 993 F.3d 388 (5th Cir. 2021) (movant must satisfy three-part framework for compassionate release)
- United States v. Cooper, 996 F.3d 283 (5th Cir. 2021) (guidance on applicability of Sentencing Commission policy statement)
- United States v. Thompson, 984 F.3d 431 (5th Cir. 2021) (§1B1.13 commentary is informative though not binding for inmate-filed motions)
- United States v. Chambliss, 948 F.3d 691 (5th Cir. 2020) (compassionate release is discretionary and §3553(a) factors can justify denial despite qualifying medical conditions)
- United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (rehabilitation alone is not an extraordinary and compelling reason)