Justin K. Eaton v. United States

Eaton filed a motion for Compassionate Release in which the par­ ties debated whether §1B1.13(b)(6), which authorized relief was consti­ tutional. Without even mentioning this issue, the Court issued a gen­ eric denial. When Eaton appealed, the 8th Circuit decided tooproceed without briefing, and denied him 8 days after the case was filed. Questions Presented I. Can U.S.S.G. §1B1.13(b)(6) be held to be an "excess of author­ ity" by the Commission when Congress has reviewed and rati­ fied that guideline pursuant to 28 U.S.C. §994? II. Does the 8th Circuit's practice of denying pro se inmates the opportunity to brief their appeals violate the Due Pro­ cess Clause of the 5th Amendment and the Federal Rules of Procedure? III. Does a summary denial bereft of reason satisfy the require­ ment of "Rita v. United States," 551 US 338 (2007) that the record reflects the Court considered the parties' arguments?