United States of America v. Kristina Blake

2020 DNH 182
CourtDistrict Court, D. New Hampshire
DecidedOctober 19, 2020
Docket19-cr-09-JD
StatusPublished

This text of 2020 DNH 182 (United States of America v. Kristina Blake) 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. Kristina Blake, 2020 DNH 182 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 19-cr-09-JD Opinion No. 2020 DNH 182 Kristina Blake

O R D E R

Kristina Blake moves pursuant to 18 U.S.C. § 3582(c)(1)(A)

to have her sentence reduced to time served based on the

combined effect of her history of hepatitis C and the risks

presented by the COVID-19 pandemic.1 In the alternative, she

asks the court to recommend to the Bureau of Prisons (“BOP”)

that she be allowed to spend the maximum amount of her sentence

in home confinement under 18 U.S.C. § 3624. The government

objects to the requested relief. United States Probation and

Pretrial Services has filed a report and recommendation on the

motions.

Standard of Review

The Director of the BOP may bring a motion on behalf of a

defendant to reduce the term of the defendant’s imprisonment.

1 Blake filed a motion pro se, and then her counsel was reappointed to represent her for purposes of seeking relief under § 3582(c)(1)(A) and filed a second motion. § 3582(c)(1)(A). If the Director does not file such a motion on

behalf of a defendant, the defendant may file a motion on his or

her own behalf in certain circumstances. The defendant must

have “fully exhausted all administrative rights to appeal a

failure of the BOP to bring a motion on the defendant’s behalf”

or, thirty days must have passed since the warden at the

defendant’s facility received the defendant’s request without a

response. Id.

When a defendant has satisfied the administrative exhaustion

requirement, the court may reduce a term of imprisonment based on

a finding that “extraordinary and compelling reasons warrant such

a reduction” and “after considering the factors provided in [18

U.S.C. §] 3553(a) to the extent that they are applicable.”

§ 3582(c)(1)(A). The statute also directs consideration of whether

the requested “reduction is consistent with applicable policy

statements issued by the Sentencing Commission.” § 3582(c)(1)(A).

The applicable policy statement, United States Sentencing

Guidelines § 1B1.13, was issued before § 3582(c)(1)(A) was

amended under the First Step Act of 2018 to allow defendants to

seek a reduction of their sentences in court. See United States

v. Tardif, 2020 WL 3960394, at *1 (D. Me. July 13, 2020). As a

result, courts have concluded that U.S.S.G. § 1B1.13 may guide

but does not limit the court’s authority to grant relief under

2 § 3582(c)(1)(A). That guidance provides that a defendant’s

term of imprisonment may be reduced if extraordinary and

compelling reasons warrant the reduction or the defendant meets

the age and time-served requirements and the defendant is not “a

danger to the safety of any other person or to the community”

and the reduction is consistent with the policy statement.

In addition, Application Note 1 to U.S.S.G. § 1B1.13

provides guidance as to when an extraordinary and compelling

reason to reduce a defendant’s sentence may exist. Those

reasons include medical conditions, age, family circumstances,

and extraordinary and compelling reasons “other than, or in

combination with, the reasons described.”2

Background

Blake pleaded guilty to conspiracy to distribute and

possess with intent to distribute fifty grams or more of

methamphetamine, in violation of 21 U.S.C. §§ 846 and

841(b)(l)(A)(viii), and conspiracy to knowingly possess firearms

in furtherance of a drug trafficking crime, in violation of 18

U.S.C. § 924(o). She was sentenced on November 21, 2019, to 120

2 The government also cites a BOP regulation from BOP Program Statement 5050.50 as providing additional guidance for sentence reduction under § 3582(c)(1)(A). The cited parts of the regulation, however, do not appear to be material to Blake’s motion.

3 months in prison. Her current release date, with good conduct

time, is October 31, 2027. She has served only 14% of her full

term. Blake is serving her sentence in a low security facility

at the Federal Correctional Institute in Danbury, Connecticut

(“FCI Danbury”).

Blake is thirty years old and has had hepatitis C since

2015 as a result of intravenous drug use. The government

consulted with Dr. J. Gavin Muir, Chief Medical Officer of

Amoskeag Health in Manchester, New Hampshire, about Blake’s

medical condition. Dr. Muir reviewed Blake’s records and

confirmed that she has had hepatitis C since 2015. Although the

records do not definitively establish that she has liver

disease, Dr. Muir concluded that it is likely that Blake does

have liver disease because of inflammation in her liver.

The CDC states that currently it has “no information about

whether people with hepatitis B or hepatitis C are at increased

risk for getting COVID-19 or having severe COVID-19.”

https://www.cdc.gov/coronavirus/2019-ncov/need-extra-

precautions/liver-disease.html (last visited September 30,

2020). The CDC also states, however, that people serious

medical conditions, might be at higher risk for severe illness

from COVID-19, particularly if the underlying medical conditions

are not well controlled.” Id.

4 As is noted above, Blake is housed at FCI Danbury. At the

time of the motions and response, there were two active cases of

COVID-19 among inmates and none among the staff at FCI Danbury.3

Blake has made requests to the warden for a motion under

§ 3582(c)(1)(A), which have been denied.

In his report, the probation officer states that Blake has

a significant criminal history, primarily involving drug

offenses. Her crime of conviction involved significant amounts

of drugs and firearms. After her arrest, Blake attempted to

coerce her codefendant to provide false information on her

behalf. She also has close ties to gangs through family members

and friends, Gangster Disciple and BOWW, which is a white

supremacist gang. She committed the crime of conviction while

she was on parole for another drug crime.

In support of her motion, Blake states that if her sentence

were reduced and she were released to home confinement, she

would live with her mother in Franklin, New Hampshire. Blake’s

thirteen-year-old child also lives with her mother. Blake

represents that she would continue to participate in programs

for her medical and mental health and for drug addiction

treatment.

3 The same numbers are reported by the BOP at www.bop.gov/coronavirus, as of October 15, 2020.

5 The probation officer reports that Blake’s mother’s home

has not been approved. The probation office called Blake’s

mother, but she did not return their calls. The probation

officer also notes that Blake’s mother threatened Blake’s

codefendant, after Blake’s arrest, that he would have problems

with Gang Disciples if he went to prison.

Discussion

Blake seeks to have her sentence changed to home

confinement for the remaining term of imprisonment, or,

alternatively, seeks a recommendation that the BOP allow the

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Related

Release of a prisoner
18 U.S.C. § 3624
Penalties
18 U.S.C. § 924(o)
Attempt and conspiracy
21 U.S.C. § 846
§ 841
21 U.S.C. § 841

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2020 DNH 182, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-kristina-blake-nhd-2020.