United States v. Pitt, 1:97-cr-00108

In 1997 Pitt was convicted of cocaine distribution and money laundering conspiracies; in 1998 the district court sentenced him to life imprisonment under the mandatory Guidelines.
The Third Circuit affirmed Pitt’s conviction and life sentence in 1999.
Pitt, age 71 and having served over 20 years, reported various health issues (heart history, dizziness, hyperlipidemia, memory loss, joint pain, kidney stones) and sought compassionate release amid the COVID-19 pandemic.
Pitt filed a pro se compassionate-release request and asked for counsel on April 13, 2020; counsel filed a supplemental motion on April 23, 2020. The government opposed.
Pitt had submitted a December 2019 request to the BOP warden, but that request explicitly was not based on medical/COVID-19 reasons. The court found he had not exhausted administrative remedies as to the COVID-19/health claims.
The court denied Pitt’s motion without prejudice for failure to exhaust administrative remedies and relied on Third Circuit precedent emphasizing strict adherence to § 3582(c)(1)(A)’s exhaustion requirement in the COVID context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pitt exhausted administrative remedies under 18 U.S.C. § 3582(c)(1)(A)	Pitt contends he requested relief from the warden (December 2019) and may proceed to court; he argues age, years served, and health justify release.	Government argues Pitt’s December 2019 BOP request did not raise COVID-19 or medical claims now advanced, so administrative exhaustion for these specific claims has not occurred.	Court held Pitt did not exhaust administrative remedies for the COVID-19/medical-based compassionate-release request and denied the motion without prejudice.
Whether extraordinary and compelling reasons justify compassionate release (age/health/COVID-19)	Pitt argues his age (71), deteriorating health conditions, and COVID-19 risk constitute extraordinary and compelling reasons warranting a sentence reduction.	Government disputed merits and opposed release; court noted BOP role and policy considerations.	Court did not reach the merits because of failure to exhaust; merits left for future consideration if exhaustion is completed.

United States v. Raia, 954 F.3d 594 (3d Cir. 2020) (third circuit requires strict compliance with § 3582(c)(1)(A) exhaustion, particularly during COVID-19)
United States v. Pitt, 193 F.3d 751 (3d Cir. 1999) (affirming Pitt’s conviction and life sentence)