Background
Terrence Smith moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The U.S. District Court for the District of Maryland granted his motion in part and reduced his sentence to 480 months’ imprisonment.
Smith appealed pro se, arguing that the amended sentence was disproportionate to the sentences imposed on his codefendants. He also asked the Fourth Circuit to decide the appeal without obtaining a response from the government.
The Court’s Holding
The Fourth Circuit affirmed, concluding that the district court did not abuse its discretion. The district court found extraordinary and compelling reasons for a reduction, weighed the 18 U.S.C. § 3553(a) factors Smith had raised, and conducted a sufficiently individualized review before selecting the amended sentence.
The appellate court also noted that Smith had not raised the codefendant-sentencing issue in his underlying motion or pro se supplements. It granted his request for a decision without the government’s response and resolved the case without oral argument.
Key Takeaways
- A district court acts within its discretion when it identifies extraordinary and compelling reasons, evaluates the relevant § 3553(a) factors, and conducts an individualized review before reducing a sentence.
- A defendant should present any argument about disparities among codefendants to the district court in the compassionate-release motion or supporting supplements.
- The Fourth Circuit affirmed Smith’s reduced 480-month sentence rather than ordering a further reduction.
Why It Matters
The decision reinforces the deferential abuse-of-discretion review applied to compassionate-release rulings and underscores the importance of preserving specific sentencing arguments in the district court.
The unpublished per curiam opinion is not binding precedent in the Fourth Circuit.