United States v. Shults
1:17-cr-00136-JLT-SKO
| E.D. Cal. | Feb 18, 2021Background
- Craig Shults was convicted under 18 U.S.C. § 115(a)(1)(B) for threatening a federal judge after prior wire‑fraud convictions and a 90‑month sentence; the § 115 conviction resulted in a consecutive 72‑month sentence.
- While incarcerated, Shults allegedly made credible, recorded threats and offered to pay inmates to kill his sentencing judge and others; a jury convicted him and the sentence was affirmed on appeal.
- Shults is serving his sentence at FCI Lompoc (projected release May 18, 2025) and filed a compassionate‑release motion under 18 U.S.C. § 3582(c)(1)(A) arguing serious medical conditions (obesity, hypertension, prior COVID‑19 infection, other ailments) and COVID‑19 risks at FCI Lompoc.
- The BOP denied his administrative request; Shults exhausted administratively and filed a district court motion (appointed counsel filed a supplement). The government opposed.
- The court found (1) administrative exhaustion satisfied, (2) Shults’s age/obesity/prior COVID‑19 could be serious, but he failed to show his conditions substantially diminish his ability to self‑care in custody, and (3) release would be inconsistent with the § 3553(a) sentencing factors given the gravity of his threats. The motion was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Administrative exhaustion | Shults submitted request to warden and appealed; therefore exhausted | N/A (government conceded exhaustion) | Court accepted concession; exhaustion satisfied and court considered merits |
| Extraordinary and compelling reasons (medical/COVID) | Obesity, hypertension, prior COVID‑19, and other conditions + outbreak at FCI Lompoc constitute extraordinary and compelling reasons for release | Government: conditions do not substantially impair self‑care; many claims not supported by BOP records; outbreak controlled | Court: although age/obesity/prior COVID could be serious, Shults failed to show he cannot provide self‑care in custody; no extraordinary and compelling reasons shown |
| Consistency with 18 U.S.C. § 3553(a) | Shults’s rehabilitation and COVID risk justify a sentence reduction or transfer to home confinement | Government: offense was egregious (threats, solicitation of murder); release would undermine sentencing goals | Court: release would be inconsistent with § 3553(a); seriousness and need for deterrence weigh strongly against release |
| Authority to order home confinement | As alternative relief, court could convert remaining sentence to home confinement | Government: CARES Act and § 3624 give BOP authority to place inmates in home confinement; courts lack authority to designate place of confinement | Court: declines to order home confinement; that authority belongs to BOP and converting sentence to time served is unwarranted |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (2010) (a sentence generally may not be modified after imposition except in limited circumstances)
- United States v. Sprague, 135 F.3d 1301 (9th Cir. 1998) (defendant bears the burden to show entitlement to sentence reduction)
- United States v. Rodriguez, 424 F. Supp. 3d 674 (N.D. Cal. 2019) (courts may assess "extraordinary and compelling" reasons beyond pre‑FSA policy categories)
- United States v. Rodriguez, 451 F. Supp. 3d 392 (E.D. Pa. 2020) (COVID‑19 plus medical issues and proximity to release can justify compassionate release)
- United States v. Parker, 461 F. Supp. 3d 966 (C.D. Cal. 2020) (collecting cases on district courts' interpretation of compassionate‑release standards post‑FSA)
- United States v. Holden, 452 F. Supp. 3d 964 (D. Or. 2020) (discussing compassionate release as an extraordinary relief)
- United States v. Burrill, 445 F. Supp. 3d 22 (N.D. Cal. 2020) (good‑time credit considerations in release calculations)