UNITED STATES v. AMEZCUA (2021)

United States Court of Appeals, Ninth Circuit.2021-04-16No. No. 21-10020

Summary · law.co

Holding. The court vacated the district court's order denying compassionate release and remanded the case for reconsideration under the correct legal standard that does not treat Sentencing Commission guidelines as binding.

Amezcua sought compassionate release from his sentence under federal law, arguing he had extraordinary and compelling reasons for release. The district court denied his request, relying on guidelines from the U.S. Sentencing Commission that establish criteria for such releases. However, after the district court's decision, this court decided in a related case that those Sentencing Commission guidelines are not binding requirements for compassionate release decisions, though they may still inform a judge's discretion.

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Key issues

Whether Sentencing Commission guidelines are binding in compassionate release determinations
Standard for establishing 'extraordinary and compelling' reasons for release
Scope of judicial discretion in Section 3582(c)(1)(A) motions

Procedural posture

Amezcua appealed the district court's denial of his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i).

Authorities cited

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Opinion · public domain

MEMORANDUM **

Raul Amezcua appeals from the district courts order denying his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i). The district court held that Amezcua had not shown “extraordinary and compelling” reasons warranting his release. 18 U.S.C. § 3582(c)(1)(A)(i). In doing so, the district court appears to have relied on the U.S. Sentencing Commissions policy statement in U.S. Sentencing Guidelines Manual (“U.S.S.G.”) § 1B1.13. After the district courts decision, we held that “the current version of U.S.S.G. § 1B1.13 is not an ‘applicable policy statement[ ]’ for 18 U.S.C. § 3582(c)(1)(A) motions filed by a defendant.” United States v. Aruda, No. 20-10245, 993 F.3d 797, 802 (9th Cir. Apr. 8, 2021) (per curiam). “The Sentencing Commissions statements in U.S.S.G. § 1B1.13 may inform a district courts discretion for § 3582(c)(1)(A) motions filed by a defendant, but they are not binding.” Id.

In light of our intervening decision in Aruda, we vacate and remand so that the district court can reassess Amezcuas motion for compassionate release under the standard set forth there. We offer no views as to the merits of Amezcuas § 3582(c)(1)(A)(i) motion.

VACATED AND REMANDED.