United States v. Stoll, 1:19-cr-00003-MC

Defendant Eric Stoll was sentenced on October 1, 2020 to two concurrent 108-month terms for possession with intent to distribute methamphetamine and heroin; projected release date October 1, 2026.
Stoll filed a pro se motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing onerous COVID-19 protocols at FCI Sheridan.
His complaints included wildfire smoke exposure, reduced hygiene supplies, suspension of family visits, lockdowns, and curtailed recreation and work opportunities.
He did not allege any specific medical condition exacerbated by COVID-19 or present a release plan.
The court reviewed governing law after the First Step Act and considered U.S.S.G. § 1B1.13 as nonbinding guidance.
The court denied the motion for lack of extraordinary and compelling reasons and, alternatively, after weighing the § 3553(a) factors (public safety, seriousness, deterrence).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stoll showed "extraordinary and compelling" reasons for compassionate release based on COVID-era facility conditions	United States: generalized facility grievances and general COVID risk do not constitute extraordinary and compelling reasons	Stoll: harsh lockdowns, lack of supplies/visits, wildfire smoke, and reduced programs made his custody unusually onerous	Denied — court found grievances insufficient and no specific medical vulnerability alleged
Whether the Sentencing Commission's policy statements bind the court in defendant-filed § 3582(c)(1)(A) motions	United States: USSG §1B1.13 is guidance but not controlling; district courts have discretion	Stoll: sought relief under the First Step Act framework for compassionate release	Court: Agrees district courts have discretion; USSG §1B1.13 may inform but is not binding
Whether § 3553(a) factors and danger to the community counsel against release	United States: Stoll's extensive drug distribution history and prior violent offenses show continued danger; no release plan	Stoll: argued sentence conditions justify reduction (did not rebut dangerousness)	Even if extraordinary reasons existed, court would deny under § 3553(a) due to criminal history, seriousness, and risk to community

United States v. Chen, 48 F.4th 1092 (9th Cir. 2022) (holds that, absent an applicable Sentencing Commission policy statement, district courts have discretion to determine what constitutes extraordinary and compelling reasons)
United States v. Aruda, 993 F.3d 797 (9th Cir. 2021) (explains USSG §1B1.13 does not apply to defendant-filed compassionate-release motions but may inform district court discretion)