United States v. Bailey

In United States v. Bailey, No. 23-50400 (5th Cir. Apr. 17, 2024) (unpublished), the Fifth Circuit vacated the district court’s order denying Bailey’s motion for compassionate release because that court had insufficiently explained its decision.

Bailey filed a motion for compassionate release under 18 U.S.C. § 3582(c)(1) because she was suffering from a brain tumor that she said was malignant. The district court denied that motion but gave little explanation. Here is its order in full: “The Court having considered all the pleadings in this case, the applicable factors provided in 18 U.S.C. § 3553(a), and the applicable policy statements issued by the Sentencing Commission, DENIES the Defendant’s Motion on its merits.”

The Fifth Circuit found that explanation insufficient because a district court must “provide specific factual reasons” for denying a compassionate release motion. Here, the court had only said that it conducted the appropriate analysis, but by failing to describe its analysis, the court deprived the Fifth Circuit “of its ability to conduct meaningful review.”

As the Fifth Circuit explained, “[t]he lack of explanation is concerning here because Bailey claims her tumor is malignant and that she has received inadequate treatment, and this Court has previously held that a terminal prognosis can constitute an extraordinary and compelling basis for a § 3582(c)(1) motion.” United States v. Chambliss, 948 F.3d 691, 692-93 (5th Cir. 2023).

For those reasons, the Fifth Circuit vacated the district court’s decision and remanded the case for “reconsideration consistent with this opinion.”