Compassionate Release- Sentencing Guidelines

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7^th Circuit Court of Appeals

Case Name: United States of America v. Leonard Williams

Case No.: 22-1981

Officials: Easterbrook, Brennan, and St. Eve, Circuit Judges.

Focus: Compassionate Release- Sentencing Guidelines

Williams, a federal prisoner, argued that his sentence is too long and created an “extraordinary and compelling” reason for compassionate release under 18 U.S.C. § 3582(c)(1). Williams claims that his conviction for delivery of cocaine in Illinois does not satisfy the criteria of a “serious drug felony” under § 841(b)(1)(B) as per the post-conviction decision in United States v. Ruth, 966 F.3d 642 (7th Cir. 2020). However, the court rejected this claim, citing United States v. Brock, 39 F.4th 462, 464–66 (7th Cir. 2022), which holds that Ruth does not support compassionate release. The court states that there is nothing “extraordinary” about a legal error by a district court, and the law provides methods other than compassionate release for dealing with claims of legal error. Williams also presented other arguments like his spotless conduct record in prison and completion of educational programs that would allow him to participate in society without committing additional crimes. But the court did not consider these contentions, as Williams did not present them to the Bureau of Prisons, which is required by the statute. The court held that the only reason that Williams presented to the Bureau is Ruth, and therefore, it is the only one the judiciary may consider.

Affirmed

Decided 03/13/23

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