United States v. Stanley Joseph Thompson
20-14404
| 11th Cir. | Jul 21, 2021Background:
- Stanley Thompson, a federal prisoner, moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A); the district court denied the motion and he appealed.
- Thompson argued extraordinary and compelling reasons existed because (1) his sentence is disproportionately long under pre-First Step Act § 924(c) "stacking" and would be shorter under current law, and (2) he received ineffective assistance of counsel at trial.
- The First Step Act (2018) amended § 3582(c)(1)(A) procedure, allowing prisoners to file compassionate-release motions after administrative exhaustion.
- The Sentencing Guidelines policy statement U.S.S.G. § 1B1.13 identifies four categories of "extraordinary and compelling reasons" (medical, age, family, and "other"), and its application notes limit the catch-all "other" category to reasons "as determined by the Director of the BOP."
- This Court previously held in United States v. Bryant that § 1B1.13 governs all § 3582(c)(1)(A) motions and that district courts may not expand the catch-all beyond BOP determinations; the district court here applied that rule and denied relief.
- On appeal the Eleventh Circuit affirmed, holding Thompson’s asserted grounds (First Step Act sentencing changes and ineffective counsel) do not fit § 1B1.13(A)–(C), and the § 1B1.13(D) catch-all is limited to BOP determinations.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1B1.13 is the applicable policy statement that limits courts to the Guideline categories when adjudicating compassionate-release motions | Thompson: District courts can find "extraordinary and compelling reasons" beyond § 1B1.13 and grant relief | Government/District Court: § 1B1.13 governs all § 3582(c)(1)(A) motions; the catch-all in note 1(D) is for BOP to determine | Held: § 1B1.13 applies to all § 3582(c)(1)(A) motions and confines the catch-all to BOP determinations (affirmed) |
| Whether Thompson’s First Step Act sentencing disparities constitute extraordinary and compelling reasons for release | Thompson: His § 924(c) sentence is draconian and would be shorter under current law, so this is extraordinary and compelling | Court: Sentencing-law changes are not listed in § 1B1.13(A)–(C) and cannot be supplied via the BOP-only catch-all by the court | Held: Not an extraordinary and compelling reason under § 1B1.13; relief denied |
| Whether ineffective assistance of counsel at trial is an extraordinary and compelling reason for compassionate release | Thompson: Poor trial counsel merits relief as an "other" extraordinary reason | Government/District Court: Ineffective counsel is not within § 1B1.13(A)–(C) and the court cannot invoke note 1(D) | Held: Ineffective assistance does not qualify under § 1B1.13 as adjudicated by the court; relief denied |
| Whether the district court erred in weighing § 3553(a) factors or in considering Thompson’s requested alternative sentence | Thompson: District court misapplied § 3553(a) and failed to consider his requested shorter term | Government/Court: No need to reach § 3553(a) or alternative-term issues once extraordinary reasons are lacking | Held: Court did not address § 3553(a) or alternative-term claims because lack of extraordinary reasons made them unnecessary |
Key Cases Cited
- United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (holding U.S.S.G. § 1B1.13 governs all § 3582(c)(1)(A) motions and confines the § 1B1.13 note 1(D) "other reasons" determination to the BOP)
- United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (noting standard of review: denial of a § 3582(c)(1)(A) motion is reviewed for abuse of discretion)