United States v. Rebeca Rivera
20-13939
| 11th Cir. | Sep 3, 2021Background
- Rebeca Rivera, a federal prisoner, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A) as amended by the First Step Act; the district court denied her motion and she appealed.
- Rivera argued the district court erred by treating the Sentencing Commission policy statements in U.S.S.G. § 1B1.13 as binding and by refusing to find extraordinary and compelling reasons based on her obesity and her facility’s handling of COVID-19.
- She also argued the court should reconsider the 18 U.S.C. § 3553(a) factors in light of her post‑sentencing rehabilitation.
- The district court concluded § 1B1.13 was binding, found Rivera’s obesity alone did not qualify as an extraordinary and compelling reason (given institutional COVID mitigation efforts), and therefore did not reach the § 3553(a) analysis.
- The Eleventh Circuit reviews denials of § 3582(c)(1)(A) motions for abuse of discretion and affirmed the district court’s decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred by treating U.S.S.G. § 1B1.13 as binding | § 1B1.13 should not be treated as binding on district courts considering defendant-filed motions | § 1B1.13 is an applicable, binding policy statement that must be considered | Court properly applied § 1B1.13 as binding (consistent with Bryant) |
| Whether Rivera’s obesity and the facility’s COVID-19 conditions constitute extraordinary and compelling reasons | Obesity plus alleged poor COVID control at the prison justify compassionate release | Obesity alone does not meet § 1B1.13 criteria and facility mitigation measures undercut the claim | Obesity alone did not qualify; Rivera failed to show an extraordinary and compelling reason |
| Whether the district court erred by not reconsidering § 3553(a) factors given post‑sentencing rehabilitation | § 3553(a) should be reconsidered and rehabilitation supports a sentence reduction | § 3553(a) is considered only if eligibility is shown; it cannot be an independent basis for relief | Court correctly declined to analyze § 3553(a) because Rivera was ineligible under § 1B1.13 |
Key Cases Cited
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (§ 1B1.13 is an applicable, binding policy statement for defendant-filed compassionate-release motions)
- Dillon v. United States, 560 U.S. 817 (2010) (two-step framework for sentence-reduction motions under § 3582)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (denials of § 3582(c)(1)(A) motions reviewed for abuse of discretion)
- United States v. Puentes, 803 F.3d 597 (11th Cir. 2015) (district courts lack inherent authority to modify sentences absent statute or rule)
- United States v. Khan, 794 F.3d 1288 (11th Cir. 2015) (abuse-of-discretion standards for district-court factual and legal determinations)
- United States v. Frazier, 387 F.3d 1244 (11th Cir. 2004) (en banc) (explaining deferential nature of abuse-of-discretion review)