United States v. Vickie Sanders
992 F.3d 583
| 7th Cir. | 2021Background
- Vickie Sanders pled guilty to methamphetamine-related offenses and was sentenced in 2018 to concurrent terms totaling 120 months; her conviction and sentence were affirmed on direct appeal.
- Sanders is incarcerated at FCI Coleman Low, which experienced COVID-19 and Legionnaires’ disease outbreaks in 2020.
- Sanders (age 59, former heavy smoker) has multiple medical conditions (e.g., COPD, asthma, obesity, Type II diabetes) that increase her risk of severe illness from COVID-19 and legionella.
- On July 10, 2020, Sanders moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A); the government filed a response with new medical records showing a positive COVID-19 test on July 15 and largely resolved or minimal symptoms by July 23.
- The district court denied compassionate release, concluding the § 3553(a) factors (seriousness of offense, dangerousness, unsuitability of home confinement because a meth lab was found in her kitchen) weighed against release; it also declined to allow a reply under Local Rule 7.1(g).
- Sanders argued on appeal that denying a reply violated due process and that the district court abused its discretion by failing to adequately consider her medical risk; the Seventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denying Sanders leave to file a reply (after government submitted new medical records) violated due process or Local Rule 7.1(g) | Sanders: new medical records raised factual matters requiring a reply; denial deprived her of opportunity to contest evidence | Government: district court has discretion under local rules; Sanders failed to show "exceptional circumstances" and court did not rely on the new records to decide relief | Court held no due process violation and no abuse of discretion—district court did not rely on new evidence, so denying a reply was proper |
| Whether the district court abused its discretion in denying compassionate release under § 3582(c)(1)(A) | Sanders: court failed to adequately consider her medical conditions and risk from legionella/COVID-19 and post-sentencing rehabilitation | Government: § 3553(a) factors (seriousness of offense, danger to community, unsuitability of home confinement) weigh against release; court reasonably considered medical records | Court held no abuse of discretion—district court reasonably weighed § 3553(a) factors and provided adequate reasons for denial |
Key Cases Cited
- Dr. Robert L. Meinders, D.C., Ltd. v. UnitedHealthcare, Inc., 800 F.3d 853 (7th Cir. 2015) (due-process principle that parties must be allowed to respond when court relies on new arguments or evidence)
- Cuevas v. United States, 317 F.3d 751 (7th Cir. 2003) (district courts have substantial discretion interpreting local rules)
- Bunn v. Khoury Enters., Inc., 753 F.3d 676 (7th Cir. 2014) (appellate restraint in reviewing district courts’ local-rule interpretations)
- United States v. Neal, 611 F.3d 399 (7th Cir. 2010) (defendant entitled to opportunity to contest propositions affecting length of imprisonment)
- United States v. Saunders, 986 F.3d 1076 (7th Cir. 2021) (standards for district-court discretion on compassionate-release motions under § 3582)
- United States v. Gunn, 980 F.3d 1178 (7th Cir. 2020) (U.S.S.G. § 1B1.13 does not bind courts when prisoners, rather than BOP, move for compassionate release)
- United States v. Marion, 590 F.3d 475 (7th Cir. 2009) (district court must provide some statement of reasons when denying relief)
- United States v. Sanders, 909 F.3d 895 (7th Cir. 2018) (affirming Sanders’s convictions and sentence on direct appeal)