United States v. Walker
2:15-cr-20262
E.D. Mich.May 16, 2025Background
- Charles Albert Walker was convicted of three counts of aiding and abetting bank robbery and two counts of using a firearm during a crime of violence, following a string of armed bank robberies in Detroit.
- He was sentenced to 462 months (nearly 39 years) in prison under a Rule 11 plea agreement.
- Walker's direct appeal was dismissed due to an appellate waiver, his § 2255 motion was denied, and subsequent attempts to file further § 2255 motions were refused.
- Walker has filed multiple motions for compassionate release; each prior motion was denied by the district court and affirmed by the Sixth Circuit on appeal.
- In March 2025, Walker filed a third pro se motion for compassionate release, which was opposed by the government on the merits.
Issues
| Issue | Walker's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether extraordinary and compelling reasons justify a sentence reduction under § 3582(c)(1)(A) | Relied on U.S.S.G. § 1B1.3(b)(6) and personal mitigating factors | § 1B1.3(b)(6) is invalid and his circumstances do not rise to 'extraordinary and compelling' | Court found no valid extraordinary/compelling reasons |
| Applicability of Sentencing Commission policy statements | U.S.S.G. § 1B1.3(b)(6) supports motion | Sixth Circuit has declared § 1B1.3(b)(6) invalid | Followed Bricker and found policy statement invalid |
| Whether the § 3553(a) sentencing factors support release | Should favor release given rehabilitation efforts | Seriousness of offenses and prior conduct outweigh positives | Court found § 3553(a) factors weigh against release |
| Necessity of a hearing on the motion | Implied need for hearing on motion | Decided based on the briefs; no hearing required | No hearing warranted; decided on written submissions |
Key Cases Cited
- United States v. Hunter, 12 F.4th 555 (6th Cir. 2021) (sentence modifications are the exception, not the rule; compassionate release only in limited circumstances)
- United States v. Michael Jones, 980 F.3d 1098 (6th Cir. 2020) (summarizes standard under § 3582(c)(1)(A) for compassionate release)
- United States v. McKinnie, 25 F.4th 583 (6th Cir. 2022) (sets framework for reviewing compassionate release motions)
- United States v. Hampton, 985 F.3d 530 (6th Cir. 2021) (affirming denial of compassionate release absent compelling reasons)
- United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) (courts have discretion to deny compassionate release even when reasons exist)