United States v. Michael Cole
20-2557
| 3rd Cir. | Sep 23, 2021Background
- In 2016 Michael Cole pled guilty to possession with intent to distribute cocaine and cocaine base and was sentenced to 120 months’ imprisonment — 68 months below the guideline range for a career offender.
- Cole was classified as a career offender; the district court had already varied downward when imposing sentence.
- After exhausting administrative remedies, in June 2020 Cole moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing extraordinary and compelling reasons: his wife was diagnosed with multiple sclerosis after his sentencing, is the sole caregiver for their two daughters, and one daughter is chronically ill.
- The District Court empathized but denied relief, citing Cole’s long criminal history, career-offender status, and that his sentence was already well below the Guidelines; the court said it might reconsider only if Cole faced COVID‑19 health risks in prison.
- Cole appealed the denial. He later filed a second compassionate-release motion (based on his wife’s condition and rising COVID‑19 cases), which the district court also denied but that second motion is not before this court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in denying compassionate release | Cole: loss of caregiver for his children constitutes extraordinary and compelling reasons; court acknowledged requirement met but failed to grant relief | Government: district court properly weighed § 3553(a) factors (long criminal history, career‑offender status, already below‑Guidelines sentence) and denial was reasonable | Affirmed: no abuse of discretion; even assuming extraordinary reasons existed, § 3553(a) factors justified denial |
Key Cases Cited
- United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (upholding denial of sentence reduction where court previously varied downward and § 3553(a) factors did not support further reduction)
- United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (standard: appellate review for abuse of discretion of district court’s denial of compassionate release)