UNITED STATES v. TADIOS (2021)

United States Court of Appeals, Ninth Circuit.2021-08-02No. No. 20-10434

Summary · law.co

Holding. The appellate court affirmed the district court's denial of the compassionate release motion, finding that any error in citing an inapplicable guideline was harmless and that the district court's analysis of the statutory factors for release was legally sound and supported by the record.

Casey Tadios sought compassionate release from his sentence under federal law, but the district court denied his motion. On appeal, Tadios claimed the district court made errors in its legal analysis, specifically by citing an incorrect guideline section and by not properly weighing the relevant statutory factors. The appellate court found that although the district court did cite the wrong guideline, this mistake was harmless because the court went on to consider all of Tadios's arguments anyway. Additionally, the district court had an independent basis for its decision: it properly analyzed the statutory factors required by law and reasonably determined that those factors did not justify release.

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Key issues

Whether the district court erred by relying on an inapplicable sentencing guideline in evaluating a compassionate release motion
Whether any such error was harmless in light of the district court's alternative reasoning
Whether the district court properly applied statutory factors when denying compassionate release

Procedural posture

Tadios appealed the district court's order denying 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 **

Casey Tadios 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, and we affirm.

Tadios contends that the district court erred by relying on U.S.S.G. § 1B1.13 as an applicable policy statement. Although the district court incorrectly cited § 1B1.13 as an applicable policy statement, see United States v. Aruda, 993 F.3d 797, 802 (9th Cir. 2021) (§ 1B1.13 is not an applicable policy statement for § 3582(c)(1)(A) motions filed by a defendant), the court also found that it had the discretion to consider reasons beyond those provided in the Guideline and it then proceeded to consider all of the arguments Tadios advanced in support of his motion.

Thus, any error in applying § 1B1.13 was harmless.

In any event, the district court also denied Tadioss motion on the basis of the 18 U.S.C. § 3553(a) factors, which provide an independent reason for denying a compassionate release motion. See United States v. Keller, 2 F.4th 1278, 1284 (9th Cir. 2021) (“[A] district court that properly denies compassionate release need not evaluate each step.”). Contrary to Tadioss argument, the district court did not err in its § 3553(a) analysis. The record reflects that the court applied the correct legal standard, explicitly considered several of the § 3553(a) factors, and reasonably concluded that they did not support release. Accordingly, the district court did not abuse its discretion by denying Tadioss motion. See Aruda, 993 F.3d at 799 (stating standard of review); United States v. Robertson, 895 F.3d 1206, 1213 (9th Cir. 2018) (district court abuses its discretion only if its decision is illogical, implausible, or not supported by the record).

AFFIRMED.

FOOTNOTES

. To the extent Tadios faults the district court for failing to consider changes in sentencing law as a reason to grant compassionate release, the record reflects that Tadios did not make that argument before the district court. Furthermore, even if a change in sentencing law is a proper consideration in compassionate release proceedings, Tadios fails to identify on appeal any such change applicable to his case.