UNITED STATES v. AGUILA (2021)

United States Court of Appeals, Ninth Circuit.2021-06-25No. No. 20-10287

Summary · law.co

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

Aguila sought early release from his sentence under the compassionate release statute, which requires showing 'extraordinary and compelling' reasons. The district court denied his motion, relying on sentencing guidelines that it treated as binding law. However, after the district court's decision, this court decided in a separate case that those guidelines are not legally binding in compassionate release cases, though they may be considered as one factor among others.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether sentencing guidelines are binding in compassionate release motions
Standard for 'extraordinary and compelling' reasons under 18 U.S.C. § 3582(c)(1)(A)(i)
Effect of intervening appellate precedent on prior district court decisions

Procedural posture

Aguila appealed the district court's denial of his compassionate release motion.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Zalathiel Aguila appeals from the district courts order denying his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i). We have jurisdiction under 28 U.S.C. § 1291. We vacate the district courts order and remand for the district court to reconsider Aguilas motion.

The district court held that Aguila 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 relied on 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, 993 F.3d 797, 802 (9th Cir. 2021) (internal quotation marks and alterations omitted). “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 Aguilas motion for compassionate release under the standard set forth there. We offer no views as to the merits of Aguilas § 3582(c)(1)(A)(i) motion.

VACATED and REMANDED.