United States v. Marlon Clenista, 26 F.4th 566

Background

In 2016 Clenista pleaded guilty to conspiracy to distribute 500+ grams of methamphetamine and was on supervised release for a prior federal meth conviction.
On September 14, 2016 the district court adopted the Probation Office Guidelines and imposed the mandatory minimum 120‑month term of imprisonment plus five years supervised release.
Clenista filed a compassionate‑release motion under 18 U.S.C. § 3582(c)(1) in December 2020 after apparently mailing a request to the warden in July 2020.
The district court assumed, without deciding, that Clenista had shown extraordinary and compelling reasons but denied relief because the § 3553(a) sentencing factors weighed against reducing the mandatory minimum sentence.
On appeal Clenista principally argued the district court failed to consider post‑sentencing changed circumstances in its § 3553(a) balancing.
The Second Circuit (per curiam) held that mandatory minimum sentences do not bar compassionate release but affirmed the denial because the district court did not abuse its discretion in applying the § 3553(a) factors.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a defendant sentenced to a mandatory minimum is eligible for compassionate release under § 3582(c)(1)	Mandatory minimum should not preclude § 3582(c)(1) relief; district court could reduce the term	Government (and district court) accepted eligibility in practice; no textual bar	Court: Mandatory minimums do not bar compassionate release; § 3582(c)(1)(A) permits reduction of any term of imprisonment
Whether the district court abused its discretion by failing to consider post‑sentencing changed circumstances in its § 3553(a) analysis	District court failed to consider changed circumstances (e.g., COVID risk, medical issues) and should have reweighted § 3553(a) factors	District court adequately considered changed circumstances and permissibly weighed unchanged factors more heavily	Court: Presume district court considered relevant § 3553(a) factors; no abuse of discretion; affirm denial
Whether a district court may deny relief based solely on § 3553(a) without deciding extraordinary and compelling reasons	Clenista did not contest this, but argued overall error in § 3553(a) analysis	Courts may resolve motions by § 3553(a) balancing alone after assuming extraordinary and compelling reasons	Court: Permissible to deny based solely on § 3553(a); consistent with precedent

Key Cases Cited

United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (recognizing that district courts have broad discretion on compassionate release and implicitly treating mandatory‑minimum defendants as eligible)
United States v. Moore, 975 F.3d 84 (2d Cir. 2020) (standard of review: abuse of discretion for denials; de novo for statutory interpretation)
Chavez‑Meza v. United States, 138 S. Ct. 1959 (2019) (district courts must adequately explain chosen sentence to permit meaningful appellate review)
United States v. Owens, 996 F.3d 755 (6th Cir. 2021) (circuit decision holding district court erred denying compassionate release to a defendant originally given a mandatory minimum)
United States v. Black, 999 F.3d 1071 (7th Cir. 2021) (vacating and remanding where defendant had received a mandatory minimum)
United States v. Rosa, 957 F.3d 113 (2d Cir. 2020) (presumption that district court considered all relevant § 3553(a) factors absent record evidence to the contrary)
United States v. Keitt, 21 F.4th 67 (2d Cir. 2021) (district court may deny compassionate release solely on § 3553(a) grounds without deciding extraordinary and compelling reasons)
United States v. Jones, 17 F.4th 371 (2d Cir. 2021) (rejected argument that courts must rebalance § 3553(a) factors in light of the pandemic)
United States v. Borden, 564 F.3d 100 (2d Cir. 2009) (abuse‑of‑discretion standard and limits)
United States v. Verkhoglyad, 516 F.3d 122 (2d Cir. 2008) (courts need not discuss every factor or give any particular factor dispositive weight)