United States v. Matlock
5:17-cr-00115-KKC
E.D. Ky.Mar 7, 2022Background
- Defendant Martez LaJuan Edwards was convicted of conspiring to distribute ≥100 grams of a heroin/fentanyl mixture and possession with intent to distribute ≥100 grams of heroin; sentenced June 25, 2019 to 180 months imprisonment on each count, concurrent.
- Edwards filed a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that intervening Sixth Circuit case law (e.g., Havis) would prevent a career-offender classification if he were sentenced today.
- The Government contended the intervening cases would not alter Edwards’ career-offender status given his § 841 conviction and three prior Michigan controlled-substance convictions.
- Sixth Circuit authority (United States v. Jones; United States v. McKinnie) permits district courts to assess "extraordinary and compelling" reasons for inmate-filed motions but bars using non-retroactive new procedural rules (like Havis as applied non-retroactively) as extraordinary and compelling.
- The court reviewed the § 3553(a) sentencing factors (previously considered at sentencing and on prior motions) and concluded those factors did not support release.
- Edwards’ request for appointed counsel was denied because there is no statutory or constitutional right to counsel for § 3582(c)(1)(A) motions and the issues were resolvable on the record.
Issues
| Issue | Plaintiff's Argument (United States) | Defendant's Argument (Edwards) | Held |
|---|---|---|---|
| Whether intervening Sixth Circuit precedent (Havis and related cases) is an "extraordinary and compelling" reason supporting compassionate release | Havis does not change Edwards’ career-offender status; in any event, non-retroactive procedural-rule changes cannot constitute "extraordinary and compelling" reasons | Havis and related decisions would mean he no longer qualifies as a career offender and therefore his sentence should be reduced | Denied — the Sixth Circuit bars using non-retroactive procedural-rule changes (e.g., Havis) as an extraordinary and compelling reason for § 3582 relief (McKinnie controls) |
| Whether the § 3553(a) factors support a sentence reduction even if extraordinary and compelling reasons existed | The § 3553(a) factors (seriousness, deterrence, protection of public) do not support release given the nature of the offenses and criminal history | Edwards sought relief based on the changed guideline exposure from career-offender reclassification | Denied — Court reaffirmed prior consideration of § 3553(a) factors and concluded they do not warrant release |
| Whether the Sentencing Commission policy statement restricts the court’s discretion in inmate-filed motions for compassionate release | The Government relied on circuit precedent (Jones) allowing district courts discretion but noting applicable policies are guidance, not a bar | Edwards argued his changed classification under more recent law justifies relief consistent with policy statements | Held for Government — district court has discretion, but binding circuit precedent and § 3553(a) analysis control the outcome |
| Whether counsel should be appointed to represent Edwards on the § 3582 motion | Appointment not required; issues are straightforward and resolvable on the record | Requested appointment of counsel to litigate the motion | Denied — no constitutional/statutory right to counsel for § 3582 motions and court could resolve issues from the record |
Key Cases Cited
- United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (district courts have discretion to determine "extraordinary and compelling" reasons when inmates file § 3582 motions)
- United States v. Havis, 927 F.3d 382 (6th Cir. 2019) (career-offender analysis of inchoate controlled-substance offenses)
- United States v. McKinnie, 24 F.4th 583 (6th Cir. 2022) (holding Havis errors do not provide "extraordinary and compelling" reasons for § 3582 relief because Havis is not retroactive)
- United States v. Webb, 565 F.3d 789 (11th Cir. 2009) (no constitutional right to counsel for § 3582 motions)