United States v. Wilford, 3:16-cr-30032

Defendant Jeffery Wilford pled guilty to distributing a substance containing heroin and was sentenced on August 14, 2017 to 94 months’ imprisonment and 7 years supervised release; projected release date December 21, 2022.
Defendant is a career offender with an extensive criminal history including violent offenses; BOP classifies him as high risk for recidivism.
Wilford filed two pro se compassionate-release motions (and an amended motion) under 18 U.S.C. § 3582(c)(1)(A), arguing medical vulnerability to COVID-19 (age 61, hypertension, obesity, prior Hepatitis C in remission, prior chest pain).
The court previously denied his first motion; he reapplied after a COVID-19 outbreak at FCI Schuylkill (facility had active cases but many recoveries reported).
Government opposed release, emphasizing public-danger and Wilford’s criminal history; Government did not raise exhaustion, so exhaustion was treated as waived.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant has "extraordinary and compelling" reasons for compassionate release (COVID + medical conditions)	Wilford’s conditions do not amount to "extraordinary and compelling" reasons; facility has mitigated spread	Age 61, hypertension, obesity (BMI 33.5), Hep C in remission, prior chest pain, plus current FCI outbreak justify release	Denied — court found medical risk insufficient to meet "extraordinary and compelling" threshold given facility context and records
Whether 18 U.S.C. § 3553(a) factors support release	Wilford poses a serious danger to the community given career-offender status, violent history, and BOP high recidivism rating	Health risks and time remaining in custody counsel for release	Denied — 3553(a) factors weigh against release due to public-danger and criminal-history considerations

United States v. Gunn, 980 F.3d 1178 (7th Cir. 2020) (failure to exhaust administrative remedies is an affirmative defense and not jurisdictional)