United States v. Vladimir Manso-Zamora, 991 F.3d 694

Appellant Vladimir Manso-Zamora was convicted in 2012 of Hobbs Act robbery offenses and three § 924(c) counts; the district court imposed a 776‑month total sentence.
In June 2020 he moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing COVID‑19 vulnerability due to prior hospitalization for bone‑marrow aplastic anemia, ulcerative colitis, and low white blood cells/platelets.
He also noted rehabilitative efforts and that the First Step Act would have affected his mandatory consecutive § 924(c) terms if sentenced later.
The district court denied relief, finding he had not shown extraordinary and compelling reasons and observed he appeared generally healthy; it also cited the lengthy remaining term and violent nature of his offenses.
On appeal appointed counsel moved to withdraw under Anders v. California, asserting no non‑frivolous issues; the panel considered whether Anders applies to § 3582(c) proceedings and whether counsel may withdraw.
The court held Anders procedures are not required in § 3582(c) proceedings, granted counsel’s motion to withdraw, directed appointment of new counsel, and declined to act on pro se filings while counsel represents Manso‑Zamora.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Anders withdrawal procedures in § 3582(c) proceedings	Anders protections should govern counsel withdrawal	Anders is required only where there's a constitutional right to counsel; § 3582(c) is collateral so no right exists	Anders is not required in § 3582(c) proceedings; counsel may withdraw without Anders if ethically warranted
Existence of extraordinary and compelling reasons for release (COVID risk)	Medical history (aplastic anemia, IBD, low WBC/platelets), hospitalization, and sentencing disparity justify release	District court: records show he appears generally healthy; he has not met extraordinary/compelling standard; long sentence and violent offenses weigh against release	District court denied compassionate release; appellate panel did not disturb merits in this order
Consideration of pro se motions while represented	Manso‑Zamora filed pro se motions to dismiss appeal and to appoint a medical expert	Court: represented litigant’s pro se filings should not be addressed while counsel is appointed	Court declined to consider pro se motions until new counsel appears

Anders v. California, 386 U.S. 738 (1967) (procedural framework for counsel withdrawal on a first appeal of right)
Pennsylvania v. Finley, 481 U.S. 551 (1987) (Anders protections apply only where a constitutional right to counsel exists)
Coleman v. Thompson, 501 U.S. 722 (1991) (no constitutional right to counsel in collateral postconviction proceedings)
United States v. Blake, 986 F.3d 756 (7th Cir.) (Anders not required in § 3582(c) proceedings; counsel may withdraw)
United States v. Meeks, 971 F.3d 830 (8th Cir.) (no right to appointed counsel in § 3582(c) proceedings)
United States v. Webb, 565 F.3d 789 (11th Cir.) (discretionary appointment of counsel in sentence‑reduction proceedings)
United States v. Forman, 553 F.3d 585 (7th Cir.) (no entitlement to counsel in § 3582(c) proceedings)
United States v. Legree, 205 F.3d 724 (4th Cir.) (no right to appointed counsel in compassionate‑release proceedings)