United States v. Ronregus Arnold Jordan
21-11482
11th Cir.Nov 3, 2021Background
- Ronregus Jordan, serving a 240-month federal sentence for being a felon in possession of a firearm, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A) as amended by the First Step Act.
- Jordan argued his obesity combined with his race (Black) increased his COVID-19 risk and therefore constituted "extraordinary and compelling reasons" for a sentence reduction.
- The district court denied relief, finding Jordan failed to show an extraordinary and compelling reason under U.S.S.G. § 1B1.13 and that his medical condition did not meet the policy-statement categories (terminal illness or inability to self-care).
- The district court applied U.S.S.G. § 1B1.13 as the controlling Sentencing Commission policy statement for compassionate-release motions filed by prisoners.
- Jordan appealed, arguing the district court erred in requiring consistency with § 1B1.13 and that the court clearly erred in finding he failed to prove heightened COVID risk from race plus obesity.
- The Eleventh Circuit affirmed the denial, holding Bryant and the prior-panel rule required consistency with § 1B1.13 and that the district court did not abuse its discretion on the factual showing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1B1.13 must be satisfied for prisoner-filed compassionate-release motions | § 1B1.13 is advisory post-Booker; district courts may exercise broader discretion (catch-all) | Bryant controls: any reduction must be consistent with § 1B1.13 | Court: Affirmed Bryant; § 1B1.13 consistency required under prior-panel rule |
| Whether Jordan proved "extraordinary and compelling" reasons based on obesity + race (COVID risk) | Race combined with obesity creates distinct, increased COVID risk justifying release | Jordan presented no individualized evidence showing aggregate risk; general population disparities insufficient | Court: No clear error; Jordan failed to show terminal illness or inability to self-care; general risks do not satisfy § 1B1.13 |
| Review standard for new legal arguments raised on appeal | (Jordan raised Booker/Kisor-based arguments for the first time) | New arguments are subject to plain-error review | Court: Reviewed for plain error and found no plain error under controlling precedent |
| Whether court needed to address vaccination/prior infection | Jordan noted COVID risk factors; implied vaccination/status relevant | Government raised vaccination and prior COVID as defenses | Court: Declined to reach because failure to meet § 1B1.13 was dispositive |
Key Cases Cited
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (holding district courts may not grant § 3582(c)(1)(A) reductions unless consistent with U.S.S.G. § 1B1.13)
- Booker v. United States, 543 U.S. 220 (2005) (holding the Sentencing Guidelines are advisory)
- Kisor v. Wilkie, 139 S. Ct. 2400 (2019) (addressing deference to agency interpretations)
- United States v. Dudley, 5 F.4th 1249 (11th Cir. 2021) (explaining the prior-panel precedent rule)
- United States v. Jones, 962 F.3d 1290 (11th Cir. 2020) (discussing standards of review for statutory interpretation challenges)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (stating abuse-of-discretion standard for § 3582(c)(1)(A) denials)