United States v. Mapuatuli
1:12-cr-01301
D. Haw.Feb 9, 2021Background
- Defendant Alan L. Mapuatuli was convicted of methamphetamine-distribution–related offenses (including possession of a firearm in furtherance of drug trafficking) and sentenced in 2015 to 300 months’ imprisonment followed by ten years’ supervised release.
- Approximately 98 months into his sentence, Mapuatuli moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing end-stage renal disease (on dialysis), COVID-19 with pneumonia (hospitalized), and a recent hemorrhagic stroke that produced left‑side paralysis.
- The BOP warden denied his request; Mapuatuli exhausted administrative remedies and filed his § 3582 motion. The Government filed a statement of no opposition, agreeing his health constitutes an extraordinary and compelling reason for release.
- A pending Ninth Circuit appeal briefly divested the district court of jurisdiction; the Ninth Circuit remanded so the district court could rule on the compassionate‑release motion.
- The district court found Mapuatuli met the U.S.S.G. § 1B1.13 medical criteria (serious condition, inability to self‑care in prison, lack of expected recovery for at least some conditions), and that his proposed homecare plan would provide needed medical care.
- The court weighed the § 3553(a) factors and community‑danger criteria, concluded he posed little danger given his deteriorated condition and release plan, and granted compassionate release to time served plus 14 days, with immediate commencement of his ten‑year supervised release and related probation instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion / jurisdiction while appeal pending | United States acknowledged exhaustion was satisfied and agreed remand allowed district court to act | Mapuatuli had exhausted BOP remedies and sought § 3582 relief; asked court to rule if remanded | Court found administrative exhaustion satisfied; Ninth Circuit remanded, district court had jurisdiction and proceeded to rule |
| Extraordinary and compelling reasons (medical) | Government agreed Mapuatuli’s combined medical conditions were extraordinary and compelling | Mapuatuli asserted end‑stage renal disease, COVID‑19 complications, and stroke with left‑side paralysis warranted release | Court held the combination met U.S.S.G. § 1B1.13 criteria for extraordinary and compelling reasons |
| Application of U.S.S.G. § 1B1.13 (self‑care and recovery) | United States concurred that records showed diminished self‑care and limited prognosis for recovery | Mapuatuli argued his conditions substantially impair self‑care in prison and include at least one irreversible condition | Court held Mapuatuli proved by preponderance that his conditions substantially diminish self‑care and at least one condition is not expected to recover |
| § 3553(a) factors & danger to community | Government agreed that § 3553 factors and dangerousness did not weigh against release given his deteriorated state and release plan | Mapuatuli argued release with family‑provided, skilled in‑home care serves sentencing goals and mitigates danger | Court found release consistent with § 3553(a), the release plan provided needed medical care, and Mapuatuli posed little danger; compassionate release granted |
Key Cases Cited
- Griggs v. Provident Consumer Disc. Co., 459 U.S. 56 (1982) (notice of appeal divests district court of control over matters involved in the appeal)
- Dillon v. United States, 560 U.S. 817 (2010) (finality of sentence and limits on district court’s authority to modify sentence)
- Penna v. United States, 319 F.3d 509 (9th Cir. 2003) (district court modification principles under § 3582)
- Sprague v. United States, 135 F.3d 1301 (9th Cir. 1998) (defendant bears burden to prove entitlement to relief by preponderance)
- Walton v. Arizona, 497 U.S. 639 (1990) (allocating burden of proof for mitigating circumstances)
- Ring v. Arizona, 536 U.S. 584 (2002) (limits on Walton recognized; cited for doctrinal context)