United States v. Peters, 1:16-cr-00080

Rhett Peters pleaded guilty to possession with intent to distribute controlled substances and was sentenced on May 5, 2017 to 240 months imprisonment and 3 years supervised release.
Peters previously filed a compassionate-release motion (denied June 2020) and three § 2255 motions; the Fifth Circuit denied authorization to file a successive § 2255 challenge tied to an agent’s alleged misconduct.
In the renewed § 3582(c)(1)(A) motion, Peters reasserts claims about the investigating agent’s alleged misconduct, challenges the court’s reliance on the agent’s statements for drug quantity/purity, raises COVID-19 concerns, contends his sentence is unusually long, and cites his institutional programming.
The Government did not raise exhaustion; the court notes the First Step Act requires BOP request exhaustion but declines to dismiss on that ground and proceeds to the merits.
The court treats agent-misconduct and quantity/purity arguments as successive § 2255 claims and dismisses those for lack of jurisdiction. On compassionate-release merits, the court finds no extraordinary and compelling reasons and that § 3553(a) factors weigh against release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction over agent-misconduct claims	Peters contends agent misconduct in another case undermines his sentence	These claims challenge sentence legality and should be considered under § 2255, not § 3582	Dismissed for lack of jurisdiction as successive § 2255 claims; court cannot entertain via compassionate-release motion
Administrative exhaustion under First Step Act	Peters asserts prior BOP request/exhaustion suffices (earlier COVID request)	Government did not press failure-to-exhaust; question whether prior unrelated BOP request covers new grounds	Court notes exhaustion is mandatory but, because Government did not raise it, proceeds to merits rather than dismissing
Extraordinary and compelling reasons (COVID / health)	Peters cites prior COVID vulnerability (asthma) and general pandemic risks	No current serious health issues alleged; no evidence of ongoing outbreak or infection	Denied: COVID no longer an imminent threat and does not constitute extraordinary and compelling reason
Unusually long sentence / change in law / rehabilitation	Peters claims sentence is unusually long and cites rehabilitation efforts	He has not identified a relevant change in law, has not served 10 years, and rehabilitation alone is insufficient	Denied: does not meet U.S.S.G. §1B1.13(b)(6) criteria; §3553(a) factors weigh against release

Dillon v. United States, 560 U.S. 817 (district court may not modify a sentence except in limited circumstances)
United States v. Escajeda, 58 F.4th 184 (5th Cir.) (compassionate-release cannot serve to challenge sentence legality)
United States v. Franco, 973 F.3d 465 (5th Cir.) (First Step Act exhaustion framework is mandatory)
United States v. Chambliss, 948 F.3d 691 (5th Cir.) (§3553(a) factors applicable to compassionate-release analysis)