United States v. Martin (P)

Under the U.S. Supreme Court’s recent precedent in United States v. Chavez-Meza (2018), the district court erred in not giving the defendants-appellants individualized explanations for its adverse rulings on their respective motions for sentence reductions under 18 U.S.C. § 3582(c)(2).

One appellant presented a mountain of new mitigating evidence that the sentencing court never evaluated. For example, she not only successfully pursued her GED but also became a respected tutor for other inmates and helped incarcerated women follow her footsteps in achieving their educational goals. Given her old age and marked rehabilitation, she argues that she is no longer a threat to society. The district court failed to address any of this new mitigation evidence.

The other appellant similarly has been a model inmate, using his time to create an educational and awareness tool to help his fellow inmates help each other. Prison officials trust him so much that they allow him to work outside of the prison compound. He argues that he is unlikely to recidivate due to his advanced age, deteriorating health, and stable home upon release. Given that there is no reference to this new mitigation evidence, the district court did not comply with the standards set forth in Chavez-Meza.

Vacated and remanded.

United States v. Martin (P), No. 17-6199, Feb. 26, 2019. 4th Cir. (Gregory) from DMD at Greenbelt (Titus).

Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published


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