Monisha Rhodes, a federal prisoner, appealed the denial of her motion for compassionate release. Rhodes had pleaded guilty in January 2023 to possessing more than 400 grams of fentanyl with intent to distribute while on supervised release. She was sentenced to 120 months of imprisonment, consecutive to a 24-month term for violating supervised release. In March 2024, Rhodes moved for compassionate release, citing her role as the sole caregiver for her children and her own serious medical issues exacerbated by prison conditions. She argued her circumstances were extraordinary and compelling under the sentencing guidelines. The district court assumed her reasons were compelling but denied relief, concluding that the statutory sentencing factors under 18 U.S.C. § 3553(a) weighed against it due to her extensive criminal history and the seriousness of her offense.
The Seventh Circuit affirmed the district court's decision, focusing on the application of 18 U.S.C. § 3553(a) factors. The court rejected Rhodes's argument that the district court overemphasized old, nonviolent offenses, clarifying that § 3553(a) permits consideration of a defendant's entire history and characteristics. The court emphasized that the need to protect the public from further crimes is a valid ground for denying compassionate release, particularly given Rhodes's long criminal history and the fact that she committed her current offense while on supervised release. The court also declined to reweigh the § 3553(a) factors, noting that the district court applied them logically. Regarding the denial of counsel, the court held that Rhodes failed to show she attempted to procure counsel on her own. Furthermore, the court dismissed arguments regarding the denial of counsel and Bureau of Prisons restrictions because Rhodes did not raise these issues in the district court, and appellate courts generally abstain from entertaining issues not raised below.
The decision affirms the district court's denial of compassionate release, meaning Monisha Rhodes must continue serving her sentence. The ruling reinforces that courts may deny compassionate release even when a defendant's circumstances are deemed extraordinary and compelling if the statutory sentencing factors, particularly public safety and criminal history, weigh against it. It also clarifies that appellate courts will not consider arguments regarding counsel or Bureau of Prisons restrictions if they were not first raised in the district court.
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