United States v. Terrell Hargrove, 30 F.4th 189

Background

Defendant Terrell Hargrove, serving a 103-month federal sentence (46 months for drug trafficking + 57 months for supervised-release revocation), moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i) in July 2020 citing COVID-19 outbreaks at his facilities.
Hargrove reported medical conditions: asthma, obstructive sleep apnea, and elevated blood-pressure readings (no formal hypertension diagnosis); he claimed these made severe COVID-19 complications reasonably probable.
He also emphasized clean disciplinary record in current term, completion of programming, a concrete release plan, and family support.
The district court denied relief, reasoning that Hargrove showed only that his conditions might increase risk (not an extraordinary and compelling reason) and that the § 3553(a) factors weighed against release.
On appeal Hargrove argued the district court (1) applied a forbidden bright-line CDC-based rule, (2) improperly considered § 3553(a)(2)(A) retributive factors despite a revocation component, and (3) failed to credit or explain rejection of his rehabilitation efforts.
The Fourth Circuit affirmed, concluding the district court did not adopt a bright-line rule, properly considered § 3553(a) factors, and adequately addressed rehabilitation in its balancing.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court applied a bright-line rule excluding conditions not in CDC highest-risk category	Hargrove: court limited consideration to CDC highest-tier risks and thus erred	Government/district court: court used CDC guidance as evidence and found Hargrove showed only a possible (not particularized) susceptibility	Court: did not apply a bright-line rule and did not abuse discretion; evidence failed to show extraordinary and compelling reasons
Whether retributive § 3553(a)(2)(A) factors may be considered given part of the sentence is a revocation sentence	Hargrove: retributive factors are barred when imposing revocation sentences and thus should not be used to deny reduction of that portion	Government: compassionate-release review must consider § 3553(a) to the extent applicable; Congress distinguished imposing a revocation sentence from reducing an imposed sentence	Court: § 3553(a) factors were properly considered; different statutory contexts allow consideration when deciding a reduction
Whether the district court failed to consider or explain the weight given to Hargrove's rehabilitation	Hargrove: court did not address his post-sentencing rehabilitation or explain why it was discounted	Government/district court: judge acknowledged and commended rehabilitation but found it did not outweigh the reasons supporting the original sentence; judge had sentenced Hargrove previously and considered history	Court: explanation was sufficient for meaningful review; rehabilitation was considered but did not overcome the § 3553(a) balance

Key Cases Cited

United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (guidance that § 1B1.13 is not an applicable policy statement for prisoner-filed motions but remains useful)
United States v. High, 997 F.3d 181 (4th Cir. 2021) (district court must consider § 3553(a) factors after finding extraordinary and compelling reasons)
United States v. Kibble, 992 F.3d 326 (4th Cir. 2021) (standard of review for compassionate-release denials: abuse of discretion)
Dillon v. United States, 560 U.S. 817 (2010) (distinguishing imposing a sentence from later reducing it)
Chavez-Meza v. United States, 138 S. Ct. 1959 (2018) (appellate review requires district court to set forth enough to show it considered arguments and provide reasoned basis)
United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (affirming that conditions listed by CDC as possibly increasing risk may nonetheless be insufficient in specific cases)
United States v. Thompson, 984 F.3d 431 (5th Cir. 2021) (district court not abusive in concluding well-controlled chronic conditions did not show significantly higher risk)