United States v. Morris Phillips, 21-6068

Phillips pleaded guilty (2015) to conspiracies to distribute marijuana and oxycodone and to money laundering; sentenced to 144 months (below the guideline range).
In Aug 2020 he moved for compassionate release citing chronic hepatitis B, hypocellularity, hematuria, bullet fragments in his lungs, and COVID-19 risk; counsel later supplemented the motion.
The district court denied the first motion, finding Phillips did not show extraordinary and compelling reasons under CDC guidance and refused to reweigh the § 3553(a) factors based on the general COVID-19 threat.
Phillips filed a second compassionate-release motion and a motion for reconsideration, emphasizing inadequate medical care at his facility, liver disease as a COVID risk, and rehabilitation efforts; some additional factors (age, likely deportation, low recidivism risk) were raised later in reply.
The district court denied reconsideration, finding Phillips forfeited some § 3553(a) arguments by raising them too late and that the factors he did present did not warrant changing its original § 3553(a) balance.
Phillips appealed, arguing the district court procedurally and substantively failed to give proper weight to the § 3553(a) factors; the Sixth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court procedurally erred by failing to consider Phillips's § 3553(a) arguments on reconsideration	Phillips: court gave his § 3553(a) arguments short shrift and ignored factors raised in reply	Government: the record shows the court considered the factors Phillips actually presented; late-raised arguments were forfeited	No procedural error; court considered the record and properly focused on arguments timely presented
Whether the district court substantively abused its discretion in weighing § 3553(a) factors (i.e., whether COVID risk, medical care failures, and rehabilitation warranted release)	Phillips: COVID risk, untreated medical conditions, and rehabilitation justify reweighing and release	Government: original sentencing emphasized offense seriousness and public protection; medical- care claims belong in an Eighth Amendment action	No substantive abuse; court reasonably gave weight to offense seriousness and declined to reweigh based on generalized COVID risk or rehabilitation alone
Whether Phillips forfeited some § 3553(a) arguments by raising them for the first time in reply	Phillips: factors like age and deportation are relevant and were timely presented	Government: those factors were first raised late and thus forfeited	Forfeited; district court reasonably declined to consider last-minute arguments

United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (three-step framework for compassionate-release review and requirement to consider § 3553(a))
United States v. Elias, 984 F.3d 516 (6th Cir. 2021) (compassionate-release denial may rest on generalized COVID-19 risk)
United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (district courts have broad discretion in compassionate-release and reconsideration rulings)
Chavez-Meza v. United States, 138 S. Ct. 1959 (2018) (appellate review assesses whether the sentencing court considered parties’ arguments and provided a reasoned basis)
United States v. Boulding, 960 F.3d 774 (6th Cir. 2020) (substantive unreasonableness occurs when a court gives undue weight to some § 3553(a) factors and too little to others)