United States of America v. P Ahmad Khawaja

2020 DNH 158
CourtDistrict Court, D. New Hampshire
DecidedMarch 25, 2022
Docket18-cr-127-LM
StatusPublished

This text of 2020 DNH 158 (United States of America v. P Ahmad Khawaja) 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. P Ahmad Khawaja, 2020 DNH 158 (D.N.H. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 18-cr-127-LM Opinion No. 2020 DNH 158 P Ahmad Khawaja

ORDER

Ahmad Khawaja renews his motion for compassionate release pursuant to 18

U.S.C. § 3582(c)(1)(A), arguing that his underlying health conditions combined with

the threat of contracting COVID-19 while incarcerated at the Federal Correctional

Institution (“FCI”) Danbury warrant his release. The court previously denied

without prejudice defendant’s motion for compassionate release because defendant

had not exhausted his administrative remedies and had failed to demonstrate

through medical records or other proof that he has a medical condition that puts

him at higher risk of experiencing severe illness should he contract COVID-19.

Defendant has submitted medical records in support of his renewed motion. The

government concedes that defendant has exhausted his administrative remedies

but objects to his release. The court held a video hearing on defendant’s renewed

motion on July 22, 2020, at which defendant and his mother, Susan Bedard,

testified.

1 STANDARD OF REVIEW

A court may grant so-called “compassionate release” to a defendant under 18

U.S.C. § 3582(c)(1)(A). 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).

Where, as here, a motion for compassionate release is properly before the

court, the court must determine if defendant is eligible for release. The statutory

language quoted above requires that defendant show that “extraordinary and

compelling reasons warrant” a reduction in his sentence, that the court consider the

factors set forth in 18 U.S.C. § 3553(a) to the extent applicable, and that the

reduction be “consistent” with the Sentencing Commission’s applicable policy

statements. 18 U.S.C. § 3582(c)(1)(A). The Sentencing Commission’s policy

statement regarding compassionate release mirrors the statutory language and

2 adds the requirement that the court find that “the defendant is not a danger to the

safety of any other person or to the community, as provided in 18 U.S.C. § 3142(g).”

U.S.S.G. § 1B1.13(2). A defendant’s dangerousness is a paramount concern as a

court weighs the decision to grant a defendant early release. See United States v.

Bradshaw, No. 1:15-CR-422, 2019 WL 7605447, at *3 (M.D.N.C. Sept. 12, 2019)

(explaining overlap between dangerousness requirement in compassionate release

policy statement and § 3553(a) requirement that court consider the need to protect

the public).

In short, 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 will not pose a danger to

the safety of any other person in 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. Rasberry, No. 2:15-CR-00127-JDL, 2020 WL

3977614, at *1 (D. Me. July 14, 2020); United States v. Hilow, No. 15-CR-170-JD,

2020 WL 2851086, at *1 (D.N.H. June 2, 2020). The defendant bears the burden of

showing that he is entitled to a sentence reduction. Hilow, 2020 WL 2851086, at *3.

And the court has “broad discretion in deciding whether to grant or deny a motion

for sentence reduction.” United States v. Britton, Crim. No. 18-cr-108-LM, 2020 WL

2404969, at *2 (D.N.H. May 12, 2020) (internal quotation marks omitted).

3 BACKGROUND

On July 12, 2018, defendant was arrested for importation of a controlled

substance (MDMA). Magistrate Judge Johnstone ordered defendant detained

pending placement in a residential drug treatment program. On July 25, 2018,

defendant was released on pretrial supervision with conditions, including successful

completion of an inpatient substance abuse treatment program.

On May 2, 2019, defendant pleaded guilty to one count of importation of a

controlled substance (MDMA) in violation of 21 U.S.C. §§ 952(a), 960(a)(1), and

960(b)(3). On January 3, 2020, the court sentenced defendant to 30 months of

imprisonment and recommended that he participate in the Residential Drug Abuse

Program (“RDAP”) while incarcerated. On February 20, 2020, defendant self-

surrendered to FCI Danbury in Connecticut where he remains incarcerated.

On April 9, 2020, defendant moved for compassionate release under 18 U.S.C.

§ 3582(c)(1)(A) based on the threat to his health posed by the spread of COVID-19 in

prisons and his breathing difficulties. He argued that the court could excuse the

statutory requirement of exhaustion of administrative remedies under certain

circumstances. The court concluded that, even assuming without deciding that it

had the power to excuse the exhaustion requirement under certain circumstances,

defendant had not shown that his case presented such circumstances. The court

reasoned that excusal of the exhaustion requirement was not warranted because

defendant had not submitted sufficient proof that he suffers from a medical

condition that places him in a high-risk category under the Centers for Disease

4 Control and Prevention (“CDC”) guidelines. Specifically, although defendant alleged

that his primary care physician had prescribed him an inhaler for “breathing

difficulties” prior to his incarceration, he did not offer any medical records

supporting that contention. Defendant also admitted that his physician had not

diagnosed the source of his breathing difficulties. For these reasons, the court found

that excusal of the exhaustion requirement was not justified.

Alternatively, the court found that even if it excused the exhaustion

requirement, defendant had still failed to demonstrate an extraordinary and

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2020 DNH 158, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-p-ahmad-khawaja-nhd-2022.