United States v. Patricia Fountain, 21-1313

Patricia Fountain was convicted in 2013 of conspiracy to defraud the United States, filing false claims, and Hobbs Act extortion for using her IRS position to recruit and extort individuals to file fraudulent tax returns; she received a 228‑month prison sentence.
In August 2020 Fountain filed a pro se motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing multiple medical conditions (including obesity, abnormal lab results, migraines from adrenoleukodystrophy, cognitive decline, and mental‑health disorders) and COVID‑19 risks at Alderson FPC.
She alleged inadequate COVID mitigation at the facility (limited social distancing, testing, mask use by staff, sanitation, and ventilation).
The district court denied relief, finding her medical conditions did not amount to "extraordinary and compelling" reasons and that the § 3553(a) sentencing factors weighed against release (noting the seriousness of her offenses, in‑custody disciplinary infractions, and that she had served less than half her sentence).
The Third Circuit reviewed for abuse of discretion and summarily affirmed the district court’s denial, granting the Government’s motion for summary affirmance.

Issue	Fountain's Argument	Government's Argument	Held
Whether Fountain’s medical conditions and COVID‑19 risk constitute "extraordinary and compelling" reasons for compassionate release	Her health conditions and alleged inadequate COVID protections at Alderson FPC make her especially vulnerable and justify release	The conditions and facility circumstances do not amount to extraordinary and compelling reasons warranting release	The district court concluded they did not; the Third Circuit did not find clear error and affirmed
Whether the § 3553(a) factors support compassionate release	As a nonviolent, first‑time, white‑collar offender with health risks, release is appropriate	The seriousness of the offenses, in‑custody disciplinary infractions, little time served, public‑safety and deterrence concerns, and sentencing‑disparity goals weigh against release	The district court reasonably weighed § 3553(a) factors and denied relief; Third Circuit affirmed for abuse‑of‑discretion review

United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (articulating abuse‑of‑discretion review for district court § 3553(a) weighing in compassionate release decisions)
United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (district court may deny compassionate release after assuming extraordinary and compelling reasons exist if § 3553(a) factors counsel against release)