Background
Robert Lee Sawyer was convicted in the Middle District of Georgia in 1999 for possession with intent to distribute cocaine and possession of a firearm by a convicted felon. He was sentenced to 240 months of imprisonment followed by five years of supervised release. Prior to the Georgia conviction, he was sentenced in the Southern District of Florida to 180 months to run consecutively. In 2025, Sawyer filed a motion for compassionate release in the Georgia court, arguing he was serving the Georgia sentence and requesting a reduction based on his age and assistance to law enforcement. The government opposed the motion, arguing the Georgia sentence had already been completed and the Florida court retained jurisdiction over the remaining time.
The court’s reasoning
The court reviewed the case de novo regarding eligibility and for abuse of discretion regarding the denial. The court determined that a federal sentence commences on the date of imposition if the defendant is in exclusive federal custody and not serving another federal sentence. The court found that Sawyer’s Georgia sentence began on February 16, 1999, the day it was imposed, because he was not serving another federal sentence at that time. The court noted that the Bureau of Prisons computation sheet showed jail credit only for the period prior to the Georgia sentence, confirming the Georgia sentence had commenced. Because the Georgia sentence was completed before the motion was filed, the district court had no remaining sentence to reduce.
What it means going forward
This ruling clarifies that a district court lacks jurisdiction to grant compassionate release for a specific sentence once that sentence has been fully served, even if the defendant is still incarcerated on a consecutive sentence from a different court.
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