United States v. Sheafe, 4:16-cr-00438-RCC-JR

Defendant Adam Sheafe was convicted of conspiracy to commit bank fraud, bank fraud, and aggravated identity theft and sentenced (originally 94 months, later adjusted to 75 months); projected release August 23, 2022.
On June 24, 2021, Sheafe filed a pro se Motion for Compassionate Release seeking transfer to home confinement or a halfway house; the Federal Public Defender (FPD) found he had not exhausted administrative remedies and the government agreed.
On August 2, 2021, Sheafe filed a second pro se Motion under 18 U.S.C. § 3582(c)(1)(A) asserting "other" extraordinary and compelling reasons: a miscalculated custody classification placed him at USP Beaumont (a high-security facility), causing frequent lockdowns, inability to complete programming, and loss of contact with his children.
The FPD concluded Sheafe had exhausted administrative remedies for the second motion but characterized his claims as challenges to the execution, location, and conditions of confinement—matters more appropriate for a § 2241 habeas petition rather than a compassionate-release motion.
The Court held Sheafe’s first motion denied for failure to exhaust; denied the § 3582 motion because the Court cannot order BOP placement or home confinement and the USP Beaumont placement did not qualify as an "extraordinary and compelling" reason; the Court also explained such execution/location claims must be raised under § 2241 in the district of confinement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Exhaustion requirement for compassionate release	Sheafe sought relief without showing exhaustion in first motion (sought court action).	Government/FPD: exhaustion is mandatory and absent here.	Court denied first motion for lack of exhaustion.
2. Whether placement at USP Beaumont is "extraordinary and compelling"	Sheafe: misclassification placed him at a high-security facility far from family, causing lockdowns, lost programming, and harm to family ties—warrants reduction/home confinement.	Government/FPD: placement or classification issues are not extraordinary and compelling; they concern execution of sentence.	Court held placement at Beaumont is not an extraordinary and compelling reason for § 3582 relief.
3. Court authority to order home confinement or change facility	Sheafe asked court to order home confinement with his mother.	Government: only BOP Director may place prisoners or order home confinement.	Court held it lacks authority to order home confinement or dictate facility placement.
4. Proper procedural vehicle for location/conditions claims	Sheafe framed claims as compassionate-release grounds.	FPD/Gov: these are challenges to manner/location of execution and must be brought under § 2241 in the district of confinement.	Court agreed and declined to recharacterize the motion as a § 2241 petition because this is not the district of confinement; denied § 3582 motion.

Shaw v. Bank of America Corp., 946 F.3d 533 (9th Cir. 2019) (exhaustion requirement for certain statutory remedies is mandatory)
United States v. Ceballos, 671 F.3d 852 (9th Cir. 2011) (district court recommendations on inmate placement are not binding on BOP)
Hernandez v. Campbell, 204 F.3d 861 (9th Cir. 2000) (challenges to manner, location, or conditions of sentence execution must proceed via § 2241 in district of confinement)
Tucker v. Carlson, 925 F.2d 330 (9th Cir. 1991) (similar rule distinguishing habeas for execution challenges)
Castro v. United States, 540 U.S. 375 (2003) (courts may recharacterize pro se motions to align substance with proper legal basis)