United States v. Woods, 4:19-cr-20112

Defendant Damario Horne-McCullough pleaded guilty to possession of a firearm in furtherance of a drug-trafficking offense and was sentenced to 60 months’ imprisonment; he began serving the sentence in April 2021.
On February 18, 2022, Horne-McCullough moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), primarily citing increased COVID-19 risk from underlying health conditions.
COVID-19 vaccination had been made available to Horne-McCullough, but he refused vaccination and offered no medical evidence showing a contraindication.
The Court applied Sixth Circuit precedent holding that access to a COVID-19 vaccine generally forecloses a finding of an "extraordinary and compelling" reason for release based on COVID risk.
The Court also evaluated the 18 U.S.C. § 3553(a) factors and found they weighed against release because Horne-McCullough had served only a small portion of a five-year sentence and his offense was serious.
The Court denied the motion for compassionate release and concluded no oral argument was necessary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether COVID-19 risk and underlying conditions constitute "extraordinary and compelling" reasons for compassionate release	Vaccine availability to the defendant negates extraordinary and compelling reasons based on COVID-19 risk	Defendant claims multiple CDC-recognized risk factors create extraordinary and compelling reasons for release	Denied—vaccine availability (which defendant refused) prevents finding extraordinary and compelling reasons
Whether the defendant’s refusal to be vaccinated affects the extraordinary-and-compelling analysis	Defendant’s refusal, absent medical contraindication, undermines his claim of COVID-based extraordinary and compelling reasons	Defendant did not present evidence of a medical contraindication or other sufficient excuse for refusing vaccination	Denied—no evidence of contraindication; refusal precludes relief under Sixth Circuit precedent
Whether the § 3553(a) sentencing factors support a sentence reduction	Continued incarceration is necessary to reflect the seriousness of the offense, provide adequate punishment, and support deterrence	Defendant argues a reduction would not be contrary to the § 3553(a) factors	Denied—§ 3553(a) factors weigh against release given seriousness of offense and short time served

United States v. Lemons, 15 F.4th 747 (6th Cir. 2021) (vaccine availability generally precludes finding extraordinary and compelling reasons based on COVID-19 risk)
United States v. Traylor, 16 F.4th 485 (6th Cir. 2021) (affirming district court denial of compassionate release where defendant had been fully vaccinated)