United States v. Vicente Corona, 20-6309

Background

Vicente Corona was convicted in 2008 of drug and money‑laundering conspiracies and, because of three prior felony convictions, received an enhanced sentence of life imprisonment under 21 U.S.C. §§ 841(b)(1)(A) and 851; the conviction and sentence were affirmed on appeal.
The First Step Act (2018) reduced certain mandatory minimums (§ 401) but expressly applied only to defendants sentenced after its enactment (i.e., it is not retroactive).
In July 2020 Corona moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing a COVID‑19 outbreak at his facility, his age (51), rehabilitative efforts, family support, and the First Step Act’s reduced mandatory minimums.
The district court denied relief, finding Corona did not show extraordinary and compelling reasons: no substantiated medical conditions, age below guideline threshold, family circumstances not sufficiently dire, and § 401 inapplicable to pre‑Act sentences (using it would circumvent Congress’s intent).
On appeal the Sixth Circuit affirmed, relying chiefly on United States v. Tomes and related precedents to hold that (a) Corona’s COVID/age/rehab/family arguments did not amount to extraordinary and compelling reasons, and (b) a non‑retroactive First Step Act change cannot be used—alone or bundled with other factors—to obtain compassionate release.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Corona established "extraordinary and compelling reasons" for compassionate release based on COVID risk, age, rehabilitation, and family support	These factors, taken together, justify reducing his life sentence	Corona failed to substantiate medical risk; age and family ties are not the extraordinary circumstances required; district court properly weighed evidence	Denied: court held none of the proffered factors, individually or combined, met the extraordinary and compelling standard
Whether the First Step Act §401 sentencing change (non‑retroactive) can be treated as an extraordinary and compelling reason or combined with other factors to justify release	If §401 applied, Corona’s prior convictions wouldn’t qualify as "serious drug felonies," producing a lower guideline/mandatory minimum; that disparity supports relief	Congress expressly limited §401’s retroactivity; using §3582 to achieve the same result would circumvent congressional intent	Denied: a non‑retroactive §401 amendment does not constitute an extraordinary and compelling reason, alone or bundled with other factors
Whether the district court abused its discretion in applying the Sentencing Guidelines notes (USSG §1B1.13) and §3553(a) analysis	Court should have given more weight to combined circumstances and sentencing disparity	District court correctly exercised discretion, may deny if any §3582 prerequisite is lacking, and permissibly relied on guideline application notes	No abuse of discretion; affirmance upheld
Whether contrary panel authority (Owens) requires a different result	Corona cites permissive treatment of First Step Act arguments in combination with other factors	Tomes controls; one panel cannot overrule another; Owens cannot be followed to the extent it conflicts with Tomes	Court declines to follow Owens and applies Tomes; affirmance stands

Key Cases Cited

990 F.3d 500 (6th Cir. 2021) (holds First Step Act §401 non‑retroactive change cannot be treated as an "extraordinary and compelling" reason for compassionate release)
984 F.3d 516 (6th Cir. 2021) (clarifies district courts may deny compassionate‑release motions when any § 3582(c)(1)(A) prerequisite is lacking)
985 F.3d 530 (6th Cir. 2021) (describes compassionate‑release standard and role of § 3553(a) and extraordinary and compelling inquiry)
978 F.3d 1000 (6th Cir. 2020) (explains district courts have substantial discretion in weighing § 3582 factors)
774 F.2d 685 (6th Cir. 1985) (one panel of the Sixth Circuit may not overrule another panel)
[citation="493 F. App'x 645"] (6th Cir. 2012) (affirming Corona’s conviction and enhanced sentence)