Marlo Helmstetter v. United States

Under 18 U.S.C. §3582(c)(1)(A), a defendant who has exhausted his administrative remedies is allowed to file his own motion to reduce his prison sentence. The statute instructs a district court that it “may reduce the term of imprisonment . . . after considering the factors set forth in section 3553(a) to the extent that they are applicable, if it finds that . . . extraordinary and compelling reasons warrant such a reduction . . . and that such a reduction is consistent with applicable policy statements issued by the Sentencing Commission . . . .” The First, Second, Fifth, Sixth, Ninth, Tenth and Eleventh Circuits have concluded that this language means that “compassionate release” under the statute can be denied after considering only the 3553(a) factors, without determining whether there are extraordinary and compelling reasons that might warrant a reduction. The question presented is whether this procedural approach is consistent with the plain language of the statute, and with this Court’s decision in Concepcion v. United States, 597 U.S. 481 (2022). 1. The caption of the case contains the names of all the parties to the proceeding in the court whose judgment is sought to be reviewed.