United States v. Perlaza-Caicedo
8:17-cr-00062
| M.D. Fla. | Jun 29, 2025Background
- Juan Carlos Perlaza-Caicedo was sentenced to 168 months' imprisonment and five years of supervised release after pleading guilty to conspiracy to distribute five kilograms or more of cocaine aboard a vessel under U.S. jurisdiction.
- Perlaza filed a motion for compassionate release, citing a proposed Sentencing Guidelines amendment, alleged disparities in post-sentencing treatment of noncitizens, and personal rehabilitation.
- The government opposed the motion, arguing none of Perlaza's reasons qualify as "extraordinary and compelling" under the applicable legal standards.
- The court found Perlaza had likely exhausted administrative remedies, allowing consideration of the merits of his motion.
- The court reviewed the arguments under 18 U.S.C. § 3582(c)(1), U.S.S.G. § 1B1.13, and related precedent regarding compassionate release.
- The motion was denied because Perlaza did not demonstrate a qualifying extraordinary and compelling reason for a sentence reduction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proposed Sentencing Guideline amendment | Proposed changes constitute an intervening change in law | Proposed amendments are not yet effective or applicable | Not extraordinary and compelling under guideline policy |
| Citizen vs. noncitizen post-sentencing disparity | Disparities justify early release | Disparities are not relevant or recognized under the law | Not extraordinary and compelling; not relevant under § 3553(a) |
| Personal rehabilitation | Rehabilitation during incarceration justifies release | Rehabilitation alone does not qualify for relief | Not a standalone reason for compassionate release |
| Exhaustion of administrative remedies | Waited 30 days after request to warden before filing motion | N/A | Administrative exhaustion presumed satisfied |
Key Cases Cited
- United States v. Handlon, 97 F.4th 829 (11th Cir. 2024) (sets out standards for compassionate release and requirements for extraordinary and compelling reasons)
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (explains applicable policy statement U.S.S.G. § 1B1.13 controls for compassionate release motions)
- United States v. Giron, 15 F.4th 1343 (11th Cir. 2021) (if no extraordinary and compelling reason is shown, court cannot grant release)