United States v. Mejia
1:18-cr-00557
S.D.N.Y.Jun 22, 2021Background
- Mejia was a truck driver for a DTO that transported large quantities of cocaine, heroin, and related proceeds between California and the New York area; he was stopped and arrested on June 11, 2018 after officers found $100,000 in a hidden dash compartment and linked him by GPS/cell data to narcotics transactions.
- Mejia pled guilty to a narcotics conspiracy; Sentencing Guidelines range was 108–135 months, Probation recommended 60 months, and the court varied downward and sentenced him to 42 months on June 14, 2019.
- Mejia filed a pro se compassionate‑release motion seeking time served (about 1½ months remaining in custody) and home confinement, citing a family predisposition to diabetes, chronic abdominal pain and hematuria allegedly inadequately treated, COVID‑19 risk in BOP, and post‑offense rehabilitation.
- The Government conceded Mejia satisfied the administrative exhaustion requirement; it opposed release on the merits, disputing the severity/recency of his medical conditions and arguing COVID‑19 risk and rehabilitation do not, alone, justify release.
- The court reviewed Mejia’s medical records, facility transfer (from FDC SeaTac to Long Beach RRM), the BOP’s COVID mitigations/vaccination efforts, and 18 U.S.C. § 3553(a) sentencing factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Administrative exhaustion | Mejia requested release from warden and was denied; exhaustion complete | Govt conceded exhaustion | Exhaustion satisfied / Government waived objection |
| "Extraordinary and compelling" — predisposition to diabetes | Family history/predisposition places him at higher COVID risk | Mejia does not have diabetes; predisposition alone not high‑risk | Predisposition/family history is not extraordinary and compelling |
| Medical care and COVID risk at facility | Chronic abdominal pain, blood in urine, and alleged inadequate care; COVID in BOP creates heightened risk | Records show treatment responses; transfer to Long Beach RRM moots SeaTac conditions; pandemic alone insufficient | Medical care not shown inadequate on record; facility conditions/COVID alone do not justify release |
| Section 3553(a) / rehabilitation | Post‑offense rehabilitation (inmate companion certificates, orderly work, GED studies) supports early release | Rehabilitation alone cannot justify compassionate release; offense was serious | 3553(a) factors weigh against reducing sentence to time served; motion denied |
Key Cases Cited
- United States v. Brooker, 976 F.3d 228 (2d Cir. 2020) (district courts have discretion to identify extraordinary and compelling reasons, but rehabilitation alone cannot qualify)
- Woodford v. Ngo, 548 U.S. 81 (2006) (exhaustion doctrine allows agency opportunity to correct its errors)
- Kontrick v. Ryan, 540 U.S. 443 (2004) (claim‑processing rules can be forfeited if not timely asserted)
- Gonzalez v. Thaler, 565 U.S. 134 (2012) (jurisdictional exhaustion requirements control a court’s adjudicatory authority)
- United States v. Gotti, 433 F. Supp. 3d 613 (S.D.N.Y. 2020) (discussing limits on sentence modification and compassionate release procedures)