United States v. Raymond Shelton, 20-2456

Shelton was federally convicted and sentenced to 168 months plus 3 years supervised release; prior appeal recorded at United States v. Shelton, 364 F. App’x 733 (3d Cir. 2010).
In Feb 2014 he was released to state custody for a 17‑month parole violation; paroled Aug 17, 2015 and began federal supervised release but later absconded.
State authorities issued an attempted‑murder warrant in May 2017; Shelton was arrested May 2019 and remains in state custody on that charge, while a federal detainer was lodged because his supervised release had not run.
In Feb 2020 (through counsel) Shelton moved to lift the federal detainer conditioned on house arrest; the District Court denied that motion.
Pro se, Shelton later asked the District Court to revisit the detainer decision and sought compassionate release citing COVID‑19 risks and medical conditions; the District Court denied reconsideration (in part because he was represented) and deemed compassionate release unavailable because he was in state custody.
The Third Circuit affirmed, concluding the District Court did not abuse its discretion and lacked jurisdiction to grant compassionate release while Shelton remained in state custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the federal detainer should be lifted / supervised‑release term modified	Shelton: supervised release expired, so detainer improper; alternatively seek house arrest/home release	Government: time in state prison in 2014 does not toll supervised release only if <30 days; supervised release still runs; District Court has discretion to deny home release	Court: supervised release had not expired; District Court did not abuse discretion denying modification/home release
Whether the Government breached the plea agreement by opposing Shelton’s release	Shelton: Govt breached plea by opposing his early release request	Government: plea limited the Govt’s sentencing position, not its ability to oppose post‑sentence release requests	Court: No breach — Govt permissibly opposed the release request
Whether the District Court erred in denying compassionate release based on COVID‑19	Shelton: medical conditions and jail conditions made compassionate release appropriate; detainer blocked transfer to community corrections	Government: Court lacked jurisdiction because Shelton is in state custody	Court: District Court correctly concluded it lacked jurisdiction to grant compassionate release while Shelton remains in state custody

United States v. Melvin, 978 F.3d 49 (3d Cir. 2020) (abuse‑of‑discretion standard for modifying supervised release)
United States v. Kalb, 891 F.3d 455 (3d Cir. 2018) (abuse‑of‑discretion review for motions for reconsideration)
United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (abuse‑of‑discretion review for compassionate‑release motions)
United States v. Ibarra, 502 U.S. 1 (1991) (timely postjudgment criminal‑case rehearing motion renders decision nonfinal)
United States v. Shelton, [citation="364 F. App'x 733"] (3d Cir. 2010) (prior appeal setting out convictions and sentence)