United States v. Timothy Massey, 20-7216

Appellant Timothy L. Massey (pro se) moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), asserting his mother’s deteriorating health prevented her from continuing as caregiver for his teenage son.
The district court denied the motion in 2019 but did not address whether Massey had shown "extraordinary and compelling reasons" or consider the § 3553(a) sentencing factors; the court largely expressed sympathy but provided no substantive analysis.
This Court reviews compassionate-release denials for abuse of discretion and has applied a three-step framework: (1) whether extraordinary and compelling reasons exist; (2) consistency with Sentencing Commission policy statements; and (3) consideration of § 3553(a) factors.
The Fourth Circuit held that, because the district court failed to analyze key issues and apply governing precedent, meaningful appellate review was impossible.
The Court vacated the district court’s order and remanded for further proceedings, expressing no view on the merits of Massey’s request.

Issue	Massey’s Argument	District Court/Government Argument	Held
Whether Massey demonstrated "extraordinary and compelling reasons" for release	Family-caregiving emergency (mother unable to care for teenage son) warrants release	District court denied motion without addressing this question	Vacated and remanded because the district court did not decide or explain whether such reasons existed
Whether a sentence reduction must be consistent with applicable Sentencing Commission policy statements	Massey urged consideration of defendant-filed motions under § 1B1.13 guidance	District court did not apply or discuss the policy statement	Court noted the policy statement is helpful guidance and remanded for consideration
Whether the court considered 18 U.S.C. § 3553(a) factors	Massey argued the § 3553(a) factors support reduction given family circumstances	District court failed to address § 3553(a) factors	Remand required so the district court can consider § 3553(a) factors in its discretion
Whether the district court abused its discretion by failing to analyze and explain its decision	Massey contended the lack of analysis was arbitrary and prevented appellate review	District court relied on sympathy but offered no legal analysis	Court found the procedural defects amounted to an abuse of discretion in that meaningful review was impossible; vacated and remanded

United States v. Kibble, 992 F.3d 326 (4th Cir. 2021) (framework for reviewing compassionate-release motions)
United States v. High, 997 F.3d 181 (4th Cir. 2021) (three-step approach and role of Sentencing Commission guidance)
United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (noting § 1B1.13 remains helpful guidance when motions are filed by defendants)