Rafael Delacruz v. United States of America

2020 DNH 103
CourtDistrict Court, D. New Hampshire
DecidedJune 17, 2020
Docket18-cv-811-LM
StatusPublished

This text of 2020 DNH 103 (Rafael Delacruz v. United States of America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rafael Delacruz v. United States of America, 2020 DNH 103 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Rafael Delacruz

v. Civil No. 18-cv-811-LM Opinion No. 2020 DNH 103 United States of America

O R D E R

Petitioner, Rafael Delacruz, is serving a 144-month

sentence on three counts of distribution of a controlled

substance (heroin and fentanyl) in violation of 21 U.S.C. §

841(a)(1) and (b)(1)(C). He is currently housed at the

Strafford County House of Corrections in Dover, New Hampshire.

Delacruz requests that this court grant him compassionate

release pursuant to 18 U.S.C. § 3582(c)(1)(A) based on the

danger posed to his health by the combination of his underlying

medical conditions and the threat of contracting COVID-19 while

incarcerated. The government concedes that Delacruz has

exhausted his administrative remedies under the statute but

objects to his release. The court held a video hearing on

Delacruz’s motion on May 28, 2020, at which he and his step-

daughter, Jaileen Irizzary, testified. STANDARD OF REVIEW

A court may grant so-called “compassionate release” to a

defendant under 18 U.S.C. § 3582(c)(1)(A).1 The statute

provides, in relevant part, that:

[T]he court, upon motion of the Director of the Bureau of Prisons or upon motion of the defendant after the defendant has fully exhausted all administrative rights to appeal a failure of the Bureau of Prisons to bring a motion on the defendant’s behalf or the lapse of 30 days from the receipt of such a request by the warden of the defendant’s facility, whichever is earlier, may reduce the term of imprisonment (and may impose a term of probation or supervised release with or without conditions that does not exceed the unserved portion of the original term of imprisonment), after considering the factors set forth in section 3553(a) to the extent that they are applicable, if it finds that—

(i) extraordinary and compelling reasons warrant such a reduction

. . .

and that such a reduction is consistent with applicable policy statements issued by the Sentencing Commission.

18 U.S.C. § 3582(c)(1)(A); see also U.S.S.G. § 1B1.13

(sentencing guidelines policy statement on compassionate

release).

1 Compassionate release motions are typically filed in defendants’ criminal cases. Delacruz, however, filed the instant motion pro se in his civil proceeding under 28 U.S.C. § 2255. This irregularity makes no legal difference to the court’s analysis. All references to “defendant” in this legal standard and elsewhere in this order apply equally to Delacruz.

2 Where, as here, a motion for compassionate release is

properly before the court, the court must determine if the

defendant is eligible for release. A court may reduce a term of

imprisonment under the compassionate release provision if it:

(1) finds that extraordinary and compelling reasons warrant the

reduction; (2) finds that the defendant is not likely to be a

danger to the safety of any other person or the community; and

(3) considers the sentencing factors outlined in 18 U.S.C. §

3553(a). See 18 U.S.C. § 3582(c)(1)(A); U.S.S.G. § 1B1.13; see

also United States v. Sapp, No. 14-CR-20520, 2020 WL 515935, at

*2 (E.D. Mich. Jan. 31, 2020); United States v. Willis, 382 F.

Supp. 3d 1185, 1187 (D.N.M. 2019). The defendant has the burden

of showing that he is entitled to a sentence reduction. United

States v. Ebbers, No. S402CR11443VEC, 2020 WL 91399, at *4

(S.D.N.Y. Jan. 8, 2020). And the court has “broad discretion in

deciding whether to grant or deny a motion for sentence

reduction.” United States v. Paul Gileno, No. 3:19-CR-161-

(VAB)-1, 2020 WL 1307108, at *2 (D. Conn. Mar. 19, 2020)

(internal quotation marks omitted).

BACKGROUND

In August 2017, Delacruz pleaded guilty to three counts of

distribution of a controlled substance (heroin and fentanyl) in

violation of 21 U.S.C. § 841(a)(1) and (b)(1)(C). United States

3 v. Rafael Delacruz, 16-cr-00121-LM, (D.N.H. Aug. 18, 2017)

(“Delacruz I”), doc. no. 42 (plea agreement). On December 1,

2017, the court sentenced Delacruz to 144 months of imprisonment

and six years of supervised release. Delacruz I, doc. no. 48

(judgment). In August 2018, Delacruz filed a motion to vacate

his sentence under 28 U.S.C. § 2255, raising several claims

including ineffective assistance of trial counsel. See doc. no.

1.

On April 22, 2020, while his § 2255 motion was still

pending, Delacruz, acting pro se, filed the instant motion for

compassionate release under the docket number for his § 2255

proceeding. Doc. no. 11. Because Delacruz was represented by

counsel in the § 2255 proceeding, the court allowed counsel to

file a supplemental motion in support of Delacruz’s pro se

motion for compassionate release. Doc. no. 14. The court held

a telephone status conference with counsel for both parties on

May 14, 2020. The parties agreed that as of May 28, 2020,

Delacruz would exhaust his administrative remedies as required

under the compassionate release provision. See doc. no. 16.

Consequently, the court held a video hearing on the merits of

Delacruz’s compassionate release motion on that date.2

2 Delacruz subsequently moved to voluntarily dismiss his § 2255 petition (doc. no. 22). The court granted that request. Endorsed Order (June 9, 2020).

4 DISCUSSION

The court addresses the three prongs of the compassionate

release analysis separately below.

I. Extraordinary and Compelling Reason

The court must first consider whether Delacruz has

established an extraordinary and compelling basis for early

release. Delacruz argues that his history of asthma,

hypertension, and several other underlying health conditions put

him at a substantial risk of experiencing severe illness should

he contract COVID-19. He also avers that several inmates at

Strafford County House of Corrections have tested positive for

the virus.

The Commentary to the Sentencing Guidelines Policy

Statement regarding compassionate release identifies four

categories of “extraordinary and compelling reasons” that

justify a sentence reduction: the defendant’s medical condition;

the defendant’s age; the defendant’s family circumstances; and a

catchall category. U.S.S.G. § 1B1.13, App. Note 1. Under the

policy statement, a medical condition constitutes an

“extraordinary and compelling reason” if the defendant is

suffering from a terminal illness, or has a serious physical or

medical condition, cognitive impairment, or deteriorating

5 physical or mental health due to age “that substantially

diminishes the ability of the defendant to provide self-care

within the environment of a correctional facility and from which

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Related

Tapia v. United States
131 S. Ct. 2382 (Supreme Court, 2011)
United States v. Willis
382 F. Supp. 3d 1185 (D. New Mexico, 2019)

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2020 DNH 103, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rafael-delacruz-v-united-states-of-america-nhd-2020.