United States v. Thompson, 984 F.3d 431

Chadwick Thompson pleaded guilty to conspiracy to distribute and possess with intent to distribute methamphetamine and, as a career offender, was sentenced to 240 months' imprisonment.
He is incarcerated at FCI Texarkana and had served under eight years of his 20-year sentence when he sought relief.
Thompson is 43 and has hypertension and high cholesterol; he had a stroke over ten years earlier but reports no lingering effects.
In April–May 2020 Thompson requested compassionate release from the warden and then from the district court under 18 U.S.C. § 3582(c)(1)(A), citing COVID-19 risk; both requests were denied.
The district court found no "extraordinary and compelling reasons" for release and did not reach the § 3553(a) factors; Thompson appealed and the Fifth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Thompson's health conditions and COVID risk constitute "extraordinary and compelling reasons" under 18 U.S.C. § 3582(c)(1)(A)	Govt: Conditions are common, well-controlled, and not "extraordinary"; even if they were, Thompson remains dangerous to the community	Thompson: Hypertension, high cholesterol, and prior stroke increase his risk of severe COVID and justify compassionate release	Affirmed denial: conditions are common, controlled, not terminal or substantially diminishing self-care; not extraordinary and compelling
Whether the district court abused its discretion in denying compassionate release	Govt: District court acted within its discretion	Thompson: District court abused discretion by failing to grant release given COVID risk	No abuse of discretion: Fifth Circuit affirms district court's factual and legal assessment

United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (discusses courts' review of compassionate-release motions and balancing § 3553(a) factors)
United States v. Pawlowski, 967 F.3d 327 (3d Cir. 2020) (conceded extraordinary reasons but denial affirmed based on § 3553(a) factors)
United States v. Hernandez, 645 F.3d 709 (5th Cir. 2011) (standard of review for district-court sentencing decisions cited for abuse-of-discretion review)
United States v. Zukerman, 451 F. Supp. 3d 329 (S.D.N.Y. 2020) (granting compassionate release in COVID context for defendant with severe comorbidities and near-term release)
United States v. Rodriguez, 451 F. Supp. 3d 392 (E.D. Pa. 2020) (reducing sentence for inmate near release with serious health conditions in light of COVID-19)
United States v. Gipson, [citation="829 F. App'x 780"] (9th Cir. 2020) (affirming denial of compassionate release for defendant with preexisting conditions)
United States v. Lambert, [citation="829 F. App'x 117"] (6th Cir. 2020) (affirming denial of compassionate release for serious medical condition not warranting release)