United States v. Tyrone Bobo Johnson, 20-13245

Defendant Tyrone Johnson, a federal prisoner proceeding pro se, moved under 18 U.S.C. § 3582(c)(1)(A) for compassionate release based on hypertension and prediabetes during the COVID‑19 pandemic.
The district court denied relief for two reasons: (1) Johnson had not exhausted administrative remedies (he filed in court May 18, 2020, but his warden request was dated June 30, 2020); (2) his medical conditions did not constitute "extraordinary and compelling reasons" under applicable Sentencing Commission policy.
Johnson contracted COVID‑19 but was asymptomatic and recovered by the time the district court ruled.
The district court also denied his motion for reconsideration, which presented no new medical facts or arguments.
The Eleventh Circuit reviewed the denial for abuse of discretion (§ 3582 decisions are discretionary) and liberally construed Johnson’s pro se filings.
The Eleventh Circuit affirmed the district court: exhaustion issue did not change the outcome, and Johnson’s hypertension and prediabetes were not extraordinary and compelling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the § 3582(c)(1)(A) exhaustion requirement barred the court from hearing Johnson’s motion	Johnson conceded he filed before exhausting but asked the court to waive exhaustion for futility, inadequate relief, or undue prejudice	Government maintained exhaustion was required or at least properly enforced by the district court	Eleventh Circuit treated exhaustion as a non‑jurisdictional claim‑processing rule; even if waiver were possible, district court did not abuse discretion to deny on other grounds
Whether hypertension and prediabetes constitute "extraordinary and compelling reasons" for compassionate release	Johnson argued those conditions increased COVID‑19 risk and warranted release	Government argued the conditions do not meet the Sentencing Commission’s medical examples or the standards for extraordinary and compelling reasons; Johnson’s infection was asymptomatic and resolved	Court held medical conditions did not qualify as extraordinary and compelling; denial was within district court’s discretion
Whether denial of reconsideration was an abuse of discretion	Johnson sought reconsideration but raised no new arguments or medical facts	Government opposed; district court found no new grounds	Eleventh Circuit affirmed denial of reconsideration as within court’s discretion

United States v. Harris, 989 F.3d 908 (11th Cir. 2021) (held § 3582(c)(1)(A) exhaustion is a non‑jurisdictional claim‑processing rule and reviewed denials for abuse of discretion)
United States v. Puentes, 803 F.3d 597 (11th Cir. 2015) (a court may modify a sentence only when authorized by statute or rule)
United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) (U.S.S.G. § 1B1.13 is an applicable, binding policy statement for § 3582 motions)
United States v. Elias, 984 F.3d 515 (6th Cir. 2021) (affirmed denial of compassionate release where hypertension alone did not justify release)
Jones v. Fla. Parole Comm’n, 787 F.3d 1105 (11th Cir. 2015) (pro se filings are liberally construed)