Motion for compassionate release under 18 USC § 3582(c)(1)(A); “Extraordinary & compelling circumstances” warranting release; Medical condition; USSG § 1B1.13(b)(1)(C)

The court held that the district court did not abuse its discretion by denying defendant-Williams’s motion for compassionate release where his health problems were considered when he was sentenced and “unchanged factual circumstances” could not establish “extraordinary and compelling” reasons to support his release. And he failed to show “that he was receiving insufficient treatment and thus at risk of a serious deterioration in health.” He pled guilty to several drug offenses, FIP, and money laundering. He was sentenced to 198 months. Almost 10 years later, he moved for compassionate release based on prison officials’ allegedly inadequate treatment of his serious medical conditions, thrombophilia and recurrent deep vein thrombosis. Both these conditions existed when he was initially sentenced. They required continued blood monitoring, and he was designated a “Care Level 3” inmate. Williams claimed that after he was transferred to his current prison, the personnel were “not testing his blood frequently enough to properly monitor his warfarin dosage, putting him at risk of blood clots and ensuing complications.” The district court denied his motion, ruling that the treatment he was currently receiving “was not ‘so deficient as to warrant intervention,’” and that even if he “could show extraordinary and compelling circumstances, the sentencing factors did not support his release.” The court looked to the Sentencing Commission policy statement Williams relied on (§ 1B1.13(b)(1)(C)) to determine what constituted extraordinary and compelling reasons for compassionate release and explained that it provides that they exist “when the ‘defendant is suffering from a medical condition that requires long-term or specialized medical care that is not being provided and without which the defendant is at risk of serious deterioration in health or death.’” The court noted that “Williams’s thrombophilia diagnosis was known at sentencing, so he prudently does not rely on it alone. Instead, he argues that, although his health has not deteriorated, he is ‘at risk’ of deterioration or death from the alleged lack of adequate treatment” at his new prison. While the “district court was ‘sympathetic’ to any ‘isolated’ delays in treatment,” it found he did not meet the second and third steps of the § 1B1.13(b)(1)(C) analysis. The court held that the record supported “the district court’s factfinding.” Williams’s medical records showed the prison “has provided ongoing treatment for his thrombophilia” and its Clinical Director indicated that his condition was “‘stable and can be fully managed’” at the facility. Affirmed.