United States v. Scampitilla, 1:11-cr-00282

Scampitilla was convicted of unarmed bank robbery and sentenced on Nov. 15, 2011 to 151 months imprisonment and 3 years supervised release.
He is housed at USP Canaan with a projected release date in Aug. 2022 and has served nearly a decade.
Medical conditions: Type 2 diabetes mellitus, obesity, and hypertension, increasing his risk of severe COVID-19 complications.
He had recent transfers between facilities (including FTC Oklahoma City and USP McCreary), increasing alleged exposure; COVID-19 was present in facilities to which he was transferred.
The Government acknowledged his diabetes and did not contest the presence of COVID-19 in his facilities, effectively conceding that extraordinary and compelling reasons exist.
The Court found §3553(a) factors and danger-to-community considerations supported release and reduced his sentence to time served (plus up to 10 days BOP quarantine); supervised release remains three years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether extraordinary and compelling reasons exist (COVID risk + medical conditions)	Gov't acknowledged diabetes and facility COVID, disputed obesity/hypertension but conceded E&C satisfied	Scampitilla: diabetes, obesity, hypertension and recent transfers create high risk of severe COVID-19	Court: E&C satisfied (gov’t concession)
Whether defendant is a danger to the community	Gov't pointed to past violent criminal history as showing dangerousness	Scampitilla: violent acts were long ago; has rehabilitated, completed programs, and has release plan	Court: Not a danger; prior record given little weight
Whether §3553(a) factors support compassionate release	Gov't argued sentence should be enforced given offense seriousness	Scampitilla: nearly a decade served; ~17 months left; reduction would be a small portion of sentence; rehabilitative steps taken	Court: §3553(a) factors favor release; time served is sufficient
Whether administrative exhaustion requirement was met	Gov't did not contest exhaustion	Scampitilla: satisfied exhaustion before filing	Court: Exhaustion satisfied

United States v. Jones, 980 F.3d 1098 (6th Cir. 2020) (district courts have discretion post-First Step Act to determine what qualifies as extraordinary and compelling)
United States v. Kincaid, [citation="802 F. App'x 187"] (6th Cir. 2020) (amount of time remaining on sentence is relevant to §3553(a) analysis)
United States v. Kontrol, 554 F.3d 1089 (6th Cir. 2009) (district courts have broad discretion in fashioning sentences to satisfy §3553(a))