United States v. Miller, 2:16-cr-00269

Defendant Aragon Bellamy Miller pleaded guilty to possession of sexually explicit images of minors and was sentenced to 57 months' imprisonment.
Miller requested compassionate release to care for his mother, who has Stage 4 cancer; he alleges he submitted a written request on July 26, 2019.
The Bureau of Prisons records show the warden received Miller's request on August 28, 2019 and denied it on September 13, 2019, notifying Miller he had 20 days to appeal; Miller did not file an appeal.
The Government moved to dismiss Miller’s § 3582(c)(1)(A) compassionate-release motion for failure to exhaust administrative remedies.
The Court interpreted the statute to allow a court motion only after (a) full exhaustion of BOP administrative appeals or (b) a 30-day lapse after the warden’s receipt of the request (meaning the warden failed to act for 30 days).
Because the warden timely denied Miller’s request and Miller did not exhaust appeals, the Court dismissed Miller’s motion without prejudice; the motion to seal was granted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller satisfied § 3582(c)(1)(A) exhaustion	Miller failed to exhaust because the warden denied the request and Miller did not appeal	Miller contends the court may act 30 days after the warden received the request even if the warden denied it	Court held exhaustion required when warden timely denies; 30-day rule applies only if warden fails to act for 30 days; dismissal without prejudice

None — the opinion primarily cites unpublished district-court decisions (WL/LEXIS) and therefore did not rely on officially reported cases.