United States v. Mateo
7:17-cr-00305
S.D.N.Y.Jun 16, 2021Background
- Defendant William Mateo pled guilty (May 19, 2017) to discharging a firearm in furtherance of a crime of violence (18 U.S.C. § 924(c)) and was sentenced (Sept. 7, 2017) to 120 months' imprisonment plus five years' supervised release.
- Mateo first moved for compassionate release on June 23, 2020; the Court denied that motion following a July 17, 2020 hearing.
- Mateo renewed his compassionate release motion on May 4, 2021 (supplemented May 20, 2021); the Government opposed.
- Mateo argued changed law, medical conditions and COVID-19 outbreaks at FCI Berlin, and onerous prison conditions established "extraordinary and compelling" reasons for release.
- The Court found Mateo was fully vaccinated and there were no inmates with COVID-19 at FCI Berlin as of May 26, 2021, and concluded the pandemic-related conditions did not constitute extraordinary and compelling reasons.
- Even assuming extraordinary reasons, the Court held the 18 U.S.C. § 3553(a) factors (serious violent offense, shot at a bank teller, served ~54 months of 120) weigh against release; the renewed motion was denied (June 16, 2021).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether "extraordinary and compelling reasons" justify compassionate release under 18 U.S.C. § 3582(c)(1)(A) | Opposed release; Mateo not at high risk given vaccination and current institution status | Mateo: changed law, medical vulnerabilities, COVID outbreaks at FCI Berlin, onerous conditions | Denied — Court found no extraordinary and compelling reason (Mateo vaccinated; no active cases at facility) |
| Whether § 3553(a) factors warrant a sentence reduction | Release would undermine seriousness, deterrence, and public safety | Mateo: first offense, served ~54 months, COVID hardships support release | Denied — § 3553(a) factors (violent bank robbery; shot at teller; served < half sentence) weigh against release |
Key Cases Cited
- United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (district courts have broad discretion to consider a defendant's full slate of reasons for compassionate release; rehabilitation alone is not an extraordinary and compelling reason)