United States of America v. Damon Austin

2023 DNH 140
CourtDistrict Court, D. New Hampshire
DecidedNovember 7, 2023
Docket18-cr-102-JD
StatusPublished
Cited by1 cases

This text of 2023 DNH 140 (United States of America v. Damon Austin) 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
United States of America v. Damon Austin, 2023 DNH 140 (D.N.H. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Case No. 18-cr-102-SE Opinion No. 2023 DNH 140 Damon Austin

O R D E R

Damon Austin, who is serving an 84-month prison sentence

after pleading guilty to being a felon in possession of a

firearm, moves for compassionate release under 18 U.S.C. §

3582(c)(1)(A), seeking to serve the remainder of his sentence in

home confinement. As he did in an earlier motion for

compassionate release, see doc. no. 59, Austin argues that the

combined effects of his medical conditions and the risks

presented by COVID-19 necessitate his release from prison.

The court denied Austin’s prior motion, concluding that the

sentencing factors in 18 U.S.C. § 3553(a), which the court must

consider when ruling on a motion for compassionate release,

weighed heavily against reducing his sentence. See doc. no. 64

at 8-10. Those factors include the nature of Austin’s crime, his

criminal history of violence, and his drug use. Id.

Although nearly two years have passed since the court

denied Austin’s first motion for compassionate release, those

factors have not changed. For the same reasons that the court

provided in that order, as well as Austin’s failure to meet the procedural requirements necessary to bring a motion for

compassionate release, the court denies Austin’s present motion

for compassionate release.

In the alternative, Austin asks the court to recommend to

the Bureau of Prisons that it place him in home confinement for

the remainder of his sentence pursuant to 18 U.S.C. § 3621(b)

and § 3624(c)(2). The court declines to make the recommendation.

Background

The criminal charges against Austin arose from an

altercation in Somersworth, New Hampshire, when Austin

threatened Christopher Brown at Brown’s home with a loaded gun.

United States v. Austin, 991 F.3d 51, 54 (1st Cir. 2021). Austin

left Brown’s house in a vehicle driven by Tanya Phillips, and

Brown called the police. Id.; doc. no. 64 at 4. Officers located

and stopped Phillips’s vehicle. Austin, 991 F.3d at 54. They

found a loaded magazine on Austin and retrieved a gun from the

front seat of the vehicle. Id. While still at the scene of the

arrest, “Austin revealed in a post-Miranda statement that he was

a convicted felon.” Id. Later, during booking, he “stated that

he was a member of the Mattapan Avenue Crips street gang.” Id.

During a subsequent search of Austin’s apartment, officers found

more guns, ammunition, cocaine and crack cocaine, other drugs,

and cash. Doc. no. 64 at 4.

2 In January 2019, Austin pleaded guilty to two counts of

possession of a firearm by a prohibited person in violation of

18 U.S.C. § 922(g)(1) and § 924(a)(2). The court sentenced him

to 84 months in prison. Austin is currently serving his sentence

at FCI Otisville in Otisville, New York.

Austin seeks to serve the remainder of his sentence in home

confinement. He pursues that goal through two avenues. The first

is that he seeks compassionate release, requesting that the

court order him to be placed in home confinement pursuant to

§ 3582(c)(1)(A), which authorizes a court to reduce a

defendant’s term of imprisonment under certain circumstances.

Should the court decline to grant Austin compassionate release,

he requests that the court recommend to the BOP that it place

him in home confinement for the remainder of his sentence under

§ 3621(b) and § 3624(c)(2).

In support of both requests, Austin submits medical

records, dated December 19, 2022, that document health

conditions of obesity, hypertension, asthma, major depressive

disorder, vitamin D deficiency, reflux disease, unspecified mood

disorder, and sarcoidosis.1 He argues that his health conditions,

1 Austin provided a quote from the Mayo Clinic website to explain that “‘[s]arcoidosis is a disease characterized by the growth of tiny collections of inflammatory cells (granulomas) in any part of your body — most commonly the lungs and lymph nodes.’” Doc. no. 75 at 1 n.2.

3 which increase his risk of serious illness or death if he

contracts COVID-19, justify his move to home confinement under

all of the applicable statutes.

Discussion

Although Austin offers the same arguments in support of his

separate requests for relief, the analysis required in

considering a motion for compassionate release and a request for

a recommendation to the BOP for release to home confinement

differs in part. Therefore, the court addresses each request

separately.

I. Compassionate Release

“Before a court considers a defendant’s motion for

compassionate release, it must determine whether the defendant

has met the procedural prerequisites for bringing such a

motion.” United States v. Crosby, No. 1:17-CR-00123-JAW-01, 2020

WL 6291367, at *6 (D. Me. Oct. 27, 2020). Specifically, a court

may consider a defendant’s motion for compassionate release

“only if he has either: (1) fully exhausted all administrative

rights to appeal [BOP’s] failure to bring a compassionate

release motion on his behalf; or (2) filed a request for

compassionate release with BOP and BOP failed to respond within

30 days,” whichever is earlier. United States v. Eisenberg, 470

4 F. Supp. 3d 111, 112 (D.N.H. 2020) (citing § 3582(c)(1)(A)); see

also United States v. Texeira-Nieves, 23 F.4th 48, 52–53 (1st

Cir. 2022).

Once the defendant has satisfied the procedural

requirements, the court may grant a motion for compassionate

release if it finds “both that the defendant has presented an

‘extraordinary and compelling’ reason warranting a sentence

reduction, and that ‘such a reduction is consistent with

applicable policy statements issued by the Sentencing

Commission.’” United States v. Ruvalcaba, 26 F.4th 14, 18-19

(1st Cir. 2022) (quoting § 3582(c)(1)(A) and citation omitted).2

In addition, “the . . . court must consider any applicable

section 3553(a) factors and determine whether, in its

discretion, the reduction . . . is warranted in whole or in part

under the particular circumstances of the case.” Id. at 19

2 The court notes that the First Circuit Court of Appeals has held that courts are not bound to consider the Sentencing Commission’s policy statement regarding compassionate release motions when the motions are “prisoner-initiated,” rather than brought by the BOP. Ruvalcaba, 26 F.4th at 19-21. The Sentencing Commission, however, has proposed an amendment to its compassionate release policy statement that may make it specifically applicable to motions filed by prisoners. See United States v. Ozen, No. 1:14-CR-118, 2023 WL 4467160, at *4 (E.D. Tex. July 11, 2023). Because consideration of the applicable policy statement does not change the outcome of the court’s order, the court assumes without deciding that it should consider the statement in ruling on Austin’s motion.

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