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 denial of compassionate release and remanded for reconsideration under the correct legal standard that does not treat sentencing guidelines as binding.

Amezcua sought compassionate release from his sentence under federal law, but the district court denied his motion after finding he had not demonstrated sufficiently extraordinary and compelling circumstances. The district court appeared to have treated sentencing guidelines as binding law when evaluating his request. However, after the district court's decision, this appellate court clarified in a separate case that those guidelines are not binding in compassionate release proceedings—they may inform a judge's discretion, but courts retain independent authority to decide such motions.

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

Key issues

Whether sentencing guidelines are binding on compassionate release motions under 18 U.S.C. § 3582(c)(1)(A)
What standard applies when evaluating 'extraordinary and compelling' reasons for release
Scope of judicial discretion in compassionate release proceedings

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

No cited authorities resolved to law.co cases yet.

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.