United States v. Robert A. McChristian
20-13546
| 11th Cir. | Jun 30, 2021Background:
- McChristian pleaded guilty in 2013 to a §924(c) offense involving a destructive device and was sentenced to 360 months' imprisonment and 5 years' supervised release.
- In June 2020 he moved pro se for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing type II diabetes, the COVID-19 pandemic, and alleged illegality of his sentence.
- The district court denied relief after finding his diabetes was being treated in prison and did not substantially diminish his ability for self-care, and that COVID-19 alone did not constitute an extraordinary and compelling reason.
- The district court applied U.S.S.G. § 1B1.13 policy statements (relying on binding Eleventh Circuit precedent) and declined to consider McChristian’s sentence-illegality argument.
- The district court also expressly considered the § 3553(a) sentencing factors when denying relief.
- McChristian appealed; the Eleventh Circuit reviewed for abuse of discretion and affirmed.
Issues:
| Issue | McChristian's Argument | Government/District Court Argument | Held |
|---|---|---|---|
| Whether diabetes/COVID-19 are extraordinary and compelling reasons for release | Diabetes (requires daily insulin) plus COVID risk justify release | Diabetes was treated in BOP; condition does not substantially limit self-care; COVID alone not extraordinary | Court affirmed denial — not extraordinary/compelling on record |
| Whether U.S.S.G. § 1B1.13 applies after the First Step Act | District court improperly applied old policy statement | §1B1.13 remains applicable to prisoner-filed §3582 motions per controlling precedent | Court held §1B1.13 governs and was properly applied |
| Whether alleged illegality of sentence must be considered in compassionate-release analysis | Court should consider the legality of the sentence as an extraordinary and compelling reason | District court declined to consider sentence-illegality in this context | Court affirmed district court’s refusal to consider that argument |
| Whether § 3553(a) factors were required and properly applied | McChristian argued for relief despite offense seriousness | District court considered §3553(a) factors and weighed offense seriousness and time remaining | Court held district court properly considered §3553(a) and did not abuse discretion |
Key Cases Cited
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (U.S.S.G. §1B1.13 applies to prisoner-filed §3582 motions)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (abuse-of-discretion review for §3582(c)(1)(A) motions; exhaustion is non-jurisdictional)
- United States v. Khan, 794 F.3d 1288 (11th Cir. 2015) (standard for abuse of discretion)
- United States v. Croteau, 819 F.3d 1293 (11th Cir. 2016) (district courts may weigh §3553(a) factors in denying compassionate release)