United States v. Reese
2:16-cr-20697
E.D. Mich.Mar 10, 2022Background:
- Eugene Reese pleaded guilty to federal drug-trafficking charges in 2018 and was sentenced to 188 months’ imprisonment, to run concurrent with an undischarged state sentence; he is in federal custody with an expected release date of July 18, 2031.
- Reese moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A) after exhausting administrative remedies.
- He sought relief on three grounds: (1) the Bureau of Prisons (BOP) failed to credit him with 576 days of state custody, (2) general COVID-19-related prison conditions and restrictions, and (3) a desire to parent his children.
- The court framed the analysis under the three-step framework: (a) extraordinary and compelling reasons, (b) consistency with Sentencing Commission policy, and (c) consideration of the § 3553(a) factors.
- The court found Reese did not assert medical vulnerability and that generalized pandemic conditions and ordinary parenting burdens do not constitute extraordinary and compelling reasons; vaccine availability and case law further undercut COVID-based claims.
- The court also held it lacked authority under § 3582(c) to grant credit for time served in state custody (that power rests with the Attorney General/BOP) and directed habeas/administrative paths for such challenges. The motion was denied on March 10, 2022.
Issues:
| Issue | Plaintiff's Argument (United States) | Defendant's Argument (Reese) | Held |
|---|---|---|---|
| Whether "extraordinary and compelling reasons" exist based on COVID-19 prison conditions and Reese's desire to parent | Generalized COVID restrictions and parenting burdens do not qualify as extraordinary; vaccine availability reduces risk | Pandemic conditions in facility and need to parent children warrant compassionate release | Denied — neither prison-wide pandemic conditions nor ordinary parenting burdens are extraordinary and compelling |
| Whether the court may reduce the federal sentence to account for 576 days of prior state custody | Credit for state custody is an administrative/BOP matter; court lacks authority under § 3582(c) to grant such credit | BOP failed to credit Reese for 576 days; sentence should be reduced accordingly | Denied on § 3582(c) relief; credit challenge must be pursued administratively and, if necessary, by § 2241 habeas against the warden |
Key Cases Cited
- United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (First Step Act allows prisoners to file compassionate-release motions after administrative exhaustion)
- United States v. Alam, 960 F.3d 831 (6th Cir. 2020) (same; prisoners may move for compassionate release)
- United States v. Elias, 984 F.3d 516 (6th Cir. 2021) (three-step framework for analyzing compassionate-release motions)
- United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (standards for compassionate-release review)
- United States v. Lemons, 15 F.4th 747 (6th Cir. 2021) (incarceration during the pandemic does not constitute extraordinary and compelling reason when the defendant has access to the COVID-19 vaccine)
- United States v. Traylor, 16 F.4th 485 (6th Cir. 2021) (vaccination undermines COVID-based compassionate-release claims even with serious health conditions)
- United States v. Crozier, 259 F.3d 503 (6th Cir. 2001) (authority to grant credit for time served rests with the Attorney General/BOP)
- McClain v. Bureau of Prisons, 9 F.3d 503 (6th Cir. 1993) (prisoner challenging BOP calculations must exhaust administrative remedies)
- Roman v. Ashcroft, 340 F.3d 314 (6th Cir. 2003) (habeas under § 2241 is the proper avenue to challenge BOP custody calculations)
- United States v. Mitchell, 472 F. Supp. 3d 403 (E.D. Mich. 2020) (example of early-pandemic finding that serious medical conditions plus COVID risk could be extraordinary and compelling)
- United States v. Colburn, 516 F. Supp. 3d 28 (D. Mass. 2021) (generalized pandemic conditions affecting all inmates do not justify special compassionate-release treatment)