United States of America v. Marion Quinton Brewster
June 24, 2026·26-6064·Per Curiam·By James Taylor
The Fourth Circuit affirmed the district court's denial of a federal prisoner's motion for compassionate release. The court held that the prisoner failed to meet the ten-year service requirement necessary to claim a change in law as an extraordinary and compelling reason.
Marion Quinton Brewster appealed the district court’s order denying his motion for compassionate release under Section thirty-five eighty-two subsection c one A. Brewster argued that intervening Supreme Court decisions regarding the Armed Career Criminal Act created a disparity between his sentence and what he would receive today.
The court’s reasoning
The court reviewed the denial for abuse of discretion and legal interpretation de novo. The court noted that while a change in law can be an extraordinary and compelling reason, the Sentencing Commission’s policy statement requires the movant to have served at least ten years of imprisonment. Because Brewster had not spent ten years in prison, the court found no reversible error in the district court’s rejection of his claim.
What it means going forward
The decision confirms that prisoners must serve ten years before a change in law can support a compassionate release motion under current policy statements, though it notes the prisoner may file again once that threshold is met.
