UNITED STATES v. HATTON III (2021)

United States Court of Appeals, Fifth Circuit.2021-04-07No. No. 20-30494

Summary · law.co

Holding. The district court's denial of the compassionate release motion was vacated and remanded for reconsideration without reliance on the inapplicable Sentencing Commission policy statement.

Ray Hatton III pleaded guilty to receiving child pornography and was sentenced to over ten years in prison plus lifetime supervised release. He later sought compassionate release under federal law, but the district court rejected his request, believing it was required to apply the Sentencing Commission's policy statement on such motions. The appellate court found that the policy statement did not actually apply to prisoner-filed compassionate release requests, only to motions filed by the Bureau of Prisons director. Because the district court had applied the wrong legal standard, the case needed to be reconsidered.

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Key issues

Applicability of Sentencing Commission policy statement to compassionate release motions
Scope of 18 U.S.C. § 3582(c)(1)(A) compassionate release authority
Standard for evaluating 'extraordinary and compelling reasons' for sentence reduction

Procedural posture

The defendant appealed the district court's denial of his motion for compassionate release filed under the First Step Act amendment to 18 U.S.C. § 3582(c)(1)(A).

Authorities cited

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Opinion · public domain

Ray Hatton III pleaded guilty to receipt of child pornography in violation of 18 U.S.C. § 2252A(a)(2)(A). In 2013, he was sentenced to 121 months’ imprisonment and a lifetime of supervised release. After exhausting his administrative remedies, Hatton filed a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act. The district court denied Hattons motion. Hatton appealed.

His case was routed to this panel for consideration in tandem with No. 20-10695, United States v. Lorick, and No. 20-40543, United States v. Shkambi. Here, as in those other cases, the district court thought itself bound by the United States Sentencing Commissions “policy statement,” which sets forth substantive standards governing compassionate-release motions under § 3582(c)(1)(A). See U.S.S.G. § 1B1.13 & cmt. 1.

As we explained in Shkambi, the text of § 1B1.13 limits its applicability to “motion[s] of the Director of the Bureau of Prisons.” No. 20-40543, at 8–9 (5th Cir. Apr. 7, 2021) (quoting U.S.S.G. § 1B1.13). The district court therefore erred in considering itself bound by the policy statement in considering a prisoners § 3582 motion. On remand, the district court must consider whether Hatton has demonstrated “extraordinary and compelling reasons” justifying sentence reduction under § 3582(c)(1)(A)(i). Of course, as always, the district court also must consider the factors enumerated in § 3553(a).

The district courts order denying Hattons motion for compassionate release is VACATED, and the case is REMANDED for further proceedings consistent with this opinion.

FOOTNOTES

FOOTNOTE

Per Curiam:*

FN* Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4.