United States v. Paulson
5:21-cr-50134
| D.S.D. | Jun 12, 2025Background
- Clayton John Paulson was convicted of attempted receipt of child pornography and sentenced to 60 months in prison, with a projected release date of July 30, 2027.
- Paulson filed a pro se motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), later supplemented by his counsel; the United States opposed.
- Paulson is incarcerated at Forrest City Low FCI, and claims several health conditions, including thyroid cancer, colon polyps, back pain, tuberculosis, and hypertension.
- He argued that delays and deficiencies in his medical treatment while incarcerated constitute extraordinary and compelling reasons for early release.
- The court analyzed whether Paulson's medical care met the standards for compassionate release under the amended Sentencing Commission policy (U.S.S.G. § 1B1.13).
- The court also evaluated the 18 U.S.C. § 3553(a) sentencing factors, focusing on the nature of the offense, Paulson’s criminal history, and his conduct both before and during imprisonment.
Issues
| Issue | Paulson's Argument | United States' Argument | Held |
|---|---|---|---|
| Whether medical conditions substantially impair self-care | Health problems and delayed care greatly limit his self-care | Medical conditions are managed; not severe enough for release | No substantial impairment; not extraordinary/compelling |
| Whether needed long-term/specialized care is not provided | Delay in critical thyroid surgery warrants release | Care was timely overall; only one notable delay | Medical care was adequate despite some delay |
| Whether delay in thyroid cancer treatment was extraordinary | Five-month delay in surgery is extraordinary | Delayed but not ignored; surgery completed, condition managed | Delay not sufficient for compassionate release |
| Whether § 3553(a) factors support early release | Clean prison record, support system, job prospects | Serious underlying offense, prior flight from supervision | § 3553(a) factors weigh against early release |
Key Cases Cited
- United States v. Jones, 836 F.3d 896 (8th Cir. 2016) (defendant bears burden to show eligibility for compassionate release)
- United States v. Houck, 2 F.4th 1082 (8th Cir. 2021) (procedural exhaustion requirement for compassionate release motions)