United States v. Washington, 1:16-cr-00051

Antonio Shropshire was convicted by a jury of conspiracy to distribute and possess with intent to distribute heroin, as well as substantive drug counts.
He was sentenced to 300 months (25 years) imprisonment in March 2018.
In November 2022, Shropshire filed and later amended a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A).
Shropshire exhausted his administrative remedies prior to seeking relief in court.
The motion cited COVID-19 risks, alleged sentencing disparities, new DOJ policies, and efforts at rehabilitation as grounds for release.

Issue	Shropshire's Argument	Government's Argument	Held
COVID-19 as extraordinary reason	Liver injuries and pandemic risks justify release	Physical injury not a qualifying condition; inmate is vaccinated and facility is low risk	Not extraordinary or compelling; denied
Sentencing disparity	Sentence is greater than similarly situated defendants and median in district	Shropshire’s offense conduct more severe; individualized sentencing justified	No unwarranted disparity; denied
Applicability of 2022 DOJ memorandum	New DOJ policy would counsel lesser charges today	Shropshire's conduct involved violence, weapons, and death, so memo inapplicable	Memo does not apply; denied
Rehabilitation as a ground for release	Positive rehabilitative efforts should be considered compelling reason	Rehabilitation alone not sufficient by statute	Not legally an extraordinary or compelling reason

United States v. McCoy, 981 F.3d 271 (4th Cir. 2020) (courts are not bound by USSG or BOP definitions of 'extraordinary and compelling reasons')
United States v. Locust, 591 F. Supp. 3d 12 (E.D. Va. 2022), aff'd, No. 22-6414 (denying compassionate release where COVID-19 risk was low at institution)