United States v. Trotter
2:17-cr-00227
E.D. Wis.Sep 9, 2024Background
- Curtis T. Trotter, serving a 120-month prison sentence for three bank robberies and brandishing a firearm, filed a second motion for compassionate release in June 2024.
- He argued that having served 75% of his sentence, his age and rehabilitation efforts, and new Sentencing Guidelines amendments warranted early release.
- The court previously denied a similar COVID-19-related compassionate release motion from Trotter.
- The government opposed the motion, arguing non-exhaustion of administrative remedies and lack of extraordinary and compelling reasons for release.
- Trotter’s guideline range at sentencing was higher than the sentence imposed (120 months vs. guideline range of 171–192 months).
- His projected release date is August 2026.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility under Amendment 821 | Trotter not eligible under amendments | Sought reduction based on guideline amendments | Not eligible; amendments do not apply to his situation |
| Exhaustion of administrative remedies | Remedies not exhausted (issue exhaustion) | Claimed prior exhaustion during pandemic | No evidence of exhaustion; motion denied on this basis |
| Extraordinary and compelling reasons | Reasons cited not extraordinary | Rehabilitation, served majority of sentence, age | Not extraordinary or compelling under relevant standards |
| Sentencing factors under § 3553(a) | Sentence appropriate, public protection | Age, programming support reduction | Factors weigh against early release |
Key Cases Cited
- United States v. Gunn, 980 F.3d 1178 (7th Cir. 2020) (court discretion on what constitutes extraordinary and compelling reasons for prisoner-initiated compassionate release motions)
- United States v. Sanford, 986 F.3d 779 (7th Cir. 2021) (administrative exhaustion is a mandatory, claim-processing rule for compassionate release)
- United States v. Williams, 987 F.3d 700 (7th Cir. 2021) (issue exhaustion required—grounds presented to warden must match those raised in court)
- United States v. Thacker, 4 F.4th 569 (7th Cir. 2021) (district courts have broad discretion until Commission updates policy statement for defendant-filed compassionate release motions)
- Gall v. United States, 552 U.S. 38 (2007) (judicial discretion in sentencing)
- Kimbrough v. United States, 552 U.S. 85 (2007) (scope of sentencing discretion)