United States v. Paulino, 1:18-cr-00173

Rafael Paulino, a Dominican citizen, is serving a 151-month federal sentence after pleading guilty to involvement in a large-scale heroin and fentanyl trafficking conspiracy.
Paulino had a prior narcotics conviction in 2009, after which he was deported; he illegally reentered the U.S. before the present offense.
Paulino argued pro se for a sentence reduction based on three grounds: improper Sentencing Guidelines, deprivation of First Step Act (FSA) credits, and "extraordinary and compelling" circumstances for compassionate release.
The Court sentenced Paulino at the bottom of the stipulated Guidelines range in his plea agreement, and he is eligible for release (pending good behavior) in December 2028.
Paulino faces deportation after serving his sentence, and his motion papers were liberally construed due to his pro se status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sentencing Guidelines Calculation	Guidelines were improperly increased	Guidelines were stipulated in plea & properly calculated	No error; correct Guidelines applied
First Step Act Time Credits (FSA)	FSA credits were improperly withheld, delaying release	Prison records show FSA eligibility and participation	No FSA violation; Paulino is eligible and has access
Compassionate Release: Model Conduct	Good conduct merits sentence reduction	Model conduct is expected, not extraordinary	Not extraordinary/compelling; no grounds for early release
Compassionate Release: Personal History	Hardship, low education, deportation justify release	These factors already considered at sentencing	Not sufficient for reduction; denied

Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (submissions by pro se litigants must be liberally construed)
Hoffler v. Bezio, 726 F.3d 144 (2d Cir. 2013) (certificate of appealability standard)
Coppedge v. United States, 369 U.S. 438 (1962) (good faith standard for in forma pauperis appeals)