United States v. Riley
5:21-cr-00004
N.D. Cal.Jun 26, 2024Background
- Amanda Riley was sentenced to 60 months in federal prison after pleading guilty to one count of wire fraud for faking cancer and soliciting over $100,000 in donations under false pretenses.
- Riley cultivated an extensive social media presence to maintain her fraud, including falsifying medical records and soliciting funds from more than 300 victims.
- Following sentencing in May 2022, Riley has served about 20 months; her projected release date is March 2026.
- While incarcerated, Riley reported numerous medical issues, but medical providers consistently note a lack of objective evidence for most symptoms and suspect malingering or factitious disorder.
- Riley moved for compassionate release (to time served) under 18 U.S.C. § 3582(c)(1), or in the alternative, for a sentence reduction under § 3582(c)(2) and Amendment 821 to the U.S. Sentencing Guidelines, citing her claimed health conditions.
- The government opposed both requests, citing allegations of feigned illness and manipulation of her care, and noting no evidence that the Bureau of Prisons (BOP) failed to provide adequate medical care.
Issues
| Issue | Riley's Argument | Government's Argument | Held |
|---|---|---|---|
| Compassionate release: extraordinary/compelling reasons | Medical issues (physical and mental health) not being adequately treated warrant release. | Riley feigns illness and receives adequate care; no compelling reason for release. | No extraordinary/compelling reasons found; denied. |
| Adequacy of BOP medical/mental health care | BOP cannot treat her complex conditions, including factitious disorder. | Treatment is adequate; frequent hospitalizations do not show inadequate care. | BOP care adequate; no grounds for release. |
| Appropriateness under § 3553(a) factors | Public scrutiny and medical placement reduce recidivism risk and warrant early release. | Upward variance at sentencing justified; malingering indicates continued risk. | No change in circumstances; release not warranted. |
| Sentence reduction under Amendment 821 (zero-point rule) | Qualifies for retroactive reduction—guidelines range would be lower under new rules. | Defendant eligible, but 3553(a) factors still counsel against reduction. | Eligible but reduction denied under 3553(a) factors. |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (2010) (setting the two-step approach for sentence modifications under § 3582(c)(2))
- United States v. Keller, 2 F.4th 1278 (9th Cir. 2021) (explaining exceptions to the general rule barring modification of sentences)
- United States v. Dunn, 728 F.3d 1151 (9th Cir. 2013) (explaining district court discretion on sentence reductions)
- United States v. Wright, 46 F.4th 938 (9th Cir. 2022) (outlining the three-factor analysis for compassionate release)