United States v. Mitchell, 1:13-cr-00098

Cass Eugene Mitchell was convicted in 2013 for receipt/distribution of child pornography and sentenced to a mandatory minimum of 180 months' imprisonment, plus 300 months' supervised release.
Mitchell violated conditions of supervised release by using the internet without permission, leading to discovery of child pornography on his devices.
Mitchell moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing time served, rehabilitation, and family medical concerns.
He also sought relief under 18 U.S.C. § 3582(c)(2) (retroactive reduction based on Amendment 821 to the Sentencing Guidelines reducing 'status points').
The government opposed, raising failure to exhaust administrative remedies as a bar to relief.
Mitchell did not reply to the government’s opposition; the court considered only the written submissions.

Issue	Mitchell's Argument	Government's Argument	Held
Compassionate release eligibility under § 3582(c)(1)(A)	Satisfied prerequisites, entitled to release for compelling reasons	Did not exhaust administrative remedies; motion is premature	Defendant failed to exhaust; motion denied as premature
Eligibility for sentence reduction under Amendment 821 (§ 3582(c)(2))	Amendment 821 reduces criminal history, would lower guideline range	Guideline range set by mandatory minimum, so unaffected	Ineligible—mandatory minimum controls, no reduction

Dillon v. United States, 560 U.S. 817 (2010) (sets out limits and process for sentence modifications under § 3582)
United States v. Keller, 2 F.4th 1278 (9th Cir. 2021) (exhaustion of administrative remedies is a mandatory prerequisite in compassionate release)
United States v. Dunn, 728 F.3d 1151 (9th Cir. 2013) (two-step analysis for § 3582(c)(2) sentencing reductions)
United States v. Brito, 868 F.3d 875 (9th Cir. 2017) (court must determine new guideline range before reducing sentence under § 3582(c)(2))