United States v. Brown — Fourth Circuit upheld denial of compassionate release

Case
United States of America v. Devin Brown, a/k/a Deno Badazz
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
Gregory; Quattlebaum; Floyd
Date Decided
September 10, 2026
Docket No.
25-6778
Topics
Compassionate Release; Sentence Reduction; Criminal Appeals
Source
Read the full opinion

Background

Devin Brown, also known as Deno Badazz, moved in the U.S. District Court for the District of South Carolina for a sentence reduction or compassionate release under 18 U.S.C. § 3582(c)(1)(A). District Judge Richard Mark Gergel denied the motion on August 20, 2025.

Brown, proceeding pro se, appealed. The Fourth Circuit submitted the case for decision without oral argument on August 17, 2026.

The Court’s Holding

The Fourth Circuit affirmed the district court’s order. After reviewing the record, the panel found no reversible error in the denial of Brown’s request for a sentence reduction or compassionate release.

The unpublished per curiam opinion did not provide additional analysis of Brown’s asserted grounds for relief or the district court’s reasoning. The court also concluded that oral argument would not aid the decisional process because the record adequately presented the facts and legal contentions.

Key Takeaways

  • The Fourth Circuit upheld the denial of Brown’s motion under 18 U.S.C. § 3582(c)(1)(A).
  • The panel found no reversible error after reviewing the record.
  • The decision is unpublished and is not binding precedent in the Fourth Circuit.

Why It Matters

The decision leaves Brown’s existing sentence unchanged and the district court’s denial of compassionate release in place. Because the Fourth Circuit issued only a brief, unpublished affirmance without substantive analysis, the opinion offers little guidance for future compassionate-release motions.

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