Israel Rojas, a federal prisoner serving an 180-month sentence, filed a pro se motion for compassionate release in June 2025, citing a recent cancer diagnosis. Under 18 U.S.C. § 3582(c)(1), a defendant must exhaust administrative remedies before seeking relief from the court. The government opposed the motion, arguing primarily that Rojas had failed to exhaust these remedies, rather than contesting the merits of his medical condition. The district court issued a paperless order denying the motion solely on the ground that Rojas had not exhausted his administrative remedies. Rojas appealed, arguing that he had in fact exhausted the required steps. On appeal, the government conceded that exhaustion was satisfied, but urged the Eleventh Circuit to affirm the denial on the merits of the compassionate release claim.
The panel, writing per curiam, first addressed the exhaustion requirement. The court agreed with both parties that Rojas had satisfied the administrative exhaustion mandate of 18 U.S.C. § 3582(c)(1)(A). However, the court declined to affirm the district court's denial on the merits, even though the government argued that the record supported such a result. The Eleventh Circuit emphasized that it is a court of review, not a court of first view. Because the district court never addressed the substantive arguments regarding Rojas's cancer diagnosis or his eligibility under the sentencing guidelines, the appellate court generally will not consider issues that were not decided below. Furthermore, the government did not present its merits arguments to the district court in the first instance, and the court noted that all parties must raise arguments to the district court if they wish to rely on them on appeal. The court also highlighted that compassionate release determinations can be fact-intensive, requiring factual findings that are the proper role of the district court, not the appellate court.
The district court's denial of the compassionate release motion is vacated, and the case is remanded for the district court to address the merits of Rojas's motion. The Eleventh Circuit expressed no opinion on whether Rojas is ultimately eligible for compassionate release. The remand allows the district court to make necessary factual findings regarding Rojas's medical condition and eligibility under 18 U.S.C. § 3582(c)(1) and U.S.S.G. § 1B1.13.
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