Background
Curtis Washington, proceeding pro se, appealed the district court’s order denying his motion for compassionate release under Section 3582(c)(1)(A) of Title 18 of the United States Code. Washington argued that intervening Supreme Court decisions in Wooden versus United States and Erlinger versus United States meant he would no longer qualify for sentencing under the Armed Career Criminal Act, creating a sentencing disparity that warranted relief.
The court’s reasoning
The court reviewed the denial for abuse of discretion, ensuring the district court did not act arbitrarily or irrationally. While the court acknowledged that a sentencing disparity from a change in law can be an extraordinary and compelling reason, the Sentencing Commission’s policy statement, Section 1B1.13, requires the movant to have served at least ten years of imprisonment for such a change to qualify. The court found that Washington had not spent ten years in prison, making the factor under Section 1B1.13(b)(6) unavailable to him.
We have reviewed the record and find no reversible error in the district court’s conclusion that Washington failed to demonstrate extraordinary and compelling reasons for relief.
United States v. Washington, No. 25-6370 (4th Cir. June 23, 2026)
What it means going forward
The decision reinforces the ten-year service requirement for claiming sentencing disparities due to changes in law as an extraordinary and compelling reason for compassionate release. It leaves open the possibility for the appellant to file a new motion once the ten-year threshold is met.