United States v. Morehouse
4:19-cr-00088
E.D. Va.Aug 2, 2021Background
- Morehouse pleaded guilty to one count of distribution of child pornography and was sentenced to 84 months' imprisonment and 15 years' supervised release; he is housed at FCI Fort Dix with projected release July 8, 2026.
- Agents executed a search warrant, seized electronic devices, and Morehouse confessed to distributing child pornography during the investigation.
- Morehouse filed a pro se motion for compassionate release (Mar. 24, 2021) after the warden denied his administrative request (Feb. 23, 2021).
- He asserted extraordinary and compelling reasons based on underlying medical conditions (bulging discs, acid reflux, PTSD) and family circumstances (wife and daughter allegedly needing care); he reported receiving both COVID-19 vaccine doses by March 9, 2021.
- The Court found his cited medical conditions are not identified by the CDC as placing him at high risk of severe COVID-19, noted vaccination reduces risk of severe illness, and acknowledged ongoing COVID-19 cases at Fort Dix but found no extraordinary and compelling reason for release.
- The Court also found family-care claims unsupported and held the § 3553(a) factors (seriousness of offense, limited time served—about 14%—and deterrence) weigh against early release; the motion was denied.
Issues
| Issue | Morehouse's Argument | Government's Argument | Held |
|---|---|---|---|
| Exhaustion of administrative remedies | Warden denied his request; he exhausted by waiting >30 days | Argued exhaustion required (implicitly) | Court found exhaustion satisfied (warden denial + >30 days) |
| Medical/COVID risk as "extraordinary and compelling" | Underlying conditions and prison risk justify release | Conditions cited are not CDC-listed high-risk; vaccination reduces severe-risk | Denied — conditions are not extraordinary; vaccination undermines COVID-based claim |
| Family circumstances as extraordinary reason | Wife and daughter need him to provide/protect; wife has co-morbidities and is unvaccinated | Family-care claim unsupported; no proof wife is incapacitated or that he is sole caregiver | Denied — insufficient evidence to meet family-care standard |
| § 3553(a) factors and rehabilitation | Points to discipline-free record and programming while imprisoned | Emphasizes gravity of offense, admitted distribution conduct, and limited portion of sentence served | Denied — § 3553(a) factors (seriousness, deterrence, only ~14% served) weigh against release |
Key Cases Cited
- No controlling or persuasive authorities with official reporter citations appear in the opinion; the Court relied primarily on CDC guidance, BOP data, and unpublished district decisions for doctrinal support.