Background
Zachary Chandler, a federal prisoner proceeding pro se, appealed the district court’s denial of his motion for compassionate release under Section eighteen United States Code Section three five eight two subsection C one A. Chandler argued the district court erred in concluding that the amendment to Section eighteen United States Code Section nine two four C one was not made retroactive.
The court’s reasoning
The court granted the Government’s motion for summary affirmance. It found that Chandler failed to challenge the district court’s independently sufficient grounds for denying his motion, including the determination that sentencing factors weighed against reduction and that he did not establish an extraordinary and compelling reason based on age or other provisions. The court further held that amendments to Section nine two four C under Section four zero three of the First Step Act are not retroactive and cannot serve as an extraordinary and compelling reason for relief.
What it means going forward
The ruling confirms that sentencing disparities arising from non-retroactive amendments to firearm statutes do not qualify as extraordinary and compelling reasons for compassionate release.