United States v. Warren, 20-3456-cr

Gabriel Warren (aka Stackz) was sentenced in 2018 to 188 months for racketeering, a narcotics conspiracy, and attempted murder in aid of racketeering.
On Sept. 2, 2020 Warren (pro se) moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing COVID-19 risk and the need to care for his sick daughter.
The District Court denied the motion, finding Warren young and healthy, noting no COVID risk factors and no indication his daughter lacked proper care; it also concluded the § 3553(a) factors weighed against release given his serious, violent offenses and criminal history.
Warren filed a letter asserting he intended to file a reply; the District Court declined to await a reply as superfluous but invited a renewed motion if new facts emerged.
On appeal Warren argued the District Court abused its discretion by denying the motion without allowing a reply and that the court should have granted release based on his COVID/family circumstances and rehabilitation.
The Second Circuit affirmed, holding any procedural error was harmless and that even if extraordinary and compelling reasons existed, the § 3553(a) factors independently justified denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the District Court abused its discretion by denying compassionate release without allowing a reply	Warren: denial was premature; he should have been allowed to file a reply before ruling	Gov't: no authority requires a reply; District Court acted within discretion	No abuse of discretion; if any procedural error existed it was harmless because outcome would be the same
Whether Warren demonstrated "extraordinary and compelling reasons" (COVID risk; family caregiving)	Warren: COVID variants and sole-caregiver status for his sick daughter justify release	Gov't: Warren is young, healthy, had no COVID risk factors; no indication daughter lacked care	District Court found he did not show extraordinary and compelling reasons; appellate court assumed arguendo they might exist but still denied relief based on § 3553(a) factors
Whether the § 3553(a) factors support release	Warren: rehabilitation and clean disciplinary record reduce danger and justify release	Gov't: serious violent offenses, substantial criminal history, and commission of offense on parole weigh against release	Court held § 3553(a) factors weighed against release and were a sufficient independent basis to deny compassionate release

United States v. Holloway, 956 F.3d 660 (2d Cir. 2020) (review of denial of discretionary sentence reduction is for abuse of discretion)
United States v. Jass, 569 F.3d 47 (2d Cir. 2009) (procedural error in sentencing is subject to harmless-error analysis)