United States v. Wannakuwatte
2:14-cr-00067
| E.D. Cal. | Jun 27, 2024Background
- Defendant Deepal Wannakuwatte pleaded guilty in 2014 to one count of wire fraud in connection with a major Ponzi scheme.
- He was sentenced to 240 months in prison, 36 months of supervised release, and ordered to pay over $108 million in restitution to 157 victims.
- After serving about 124 months, Wannakuwatte filed a motion in March 2024 for sentence reduction under 18 U.S.C. § 3582(c)(1)(A) (compassionate release).
- The Defendant cited medical issues, age, time served, family circumstances, alleged BOP misconduct, rehabilitation, and COVID-19 hardships as grounds for release.
- The Government opposed the motion, and the matter was fully briefed.
- The Court considered both whether extraordinary and compelling reasons existed and whether the sentencing factors under § 3553(a) justified release.
Issues
| Issue | Wannakuwatte's Argument | Government's Argument | Held |
|---|---|---|---|
| Eligibility under § 3582(c)(1)(A) | Medical/family hardship, age, rehabilitation, and COVID-19 amount to extraordinary and compelling reasons | Opposes, denies these reasons meet the threshold | Court assumes for argument but does not decide, proceeds to § 3553(a) factors |
| Application of § 3553(a) factors | Age, health, time served, low recidivism, good conduct support reduction | Severity of crime, restitution owed, and deterrence require full sentence | § 3553(a) factors do not support reduction |
| Sentence sufficiency and public safety | Sentence served is sufficient to reflect seriousness of offense and protect public | 240-month sentence needed for just punishment and deterrence, given scope of fraud | Court agrees with Government; denies reduction |
| Rehabilitation and risk of future crimes | Rehabilitation, model inmate behavior, and low recidivism risk warrant relief | Rehabilitation alone not sufficient for reduction | Rehabilitation not enough to warrant reduction |
Key Cases Cited
- Dillon v. United States, 560 U.S. 817 (sets limits on modifying imposed sentences; addresses the structure of § 3582(c) motions)
- United States v. Keller, 2 F.4th 1278 (9th Cir. 2021) (district court need not find 'extraordinary and compelling' before denying for § 3553(a) reasons)