United States of America v. P Charles Fowle

2020 DNH 197
CourtDistrict Court, D. New Hampshire
DecidedNovember 10, 2020
Docket14-cr-093-03-LM
StatusPublished

This text of 2020 DNH 197 (United States of America v. P Charles Fowle) 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 Charles Fowle, 2020 DNH 197 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 14-cr-093-03-LM Opinion No. 2020 DNH 197 P Charles Fowle

ORDER

Charles Fowle moves for compassionate release under 18 U.S.C. §

3582(c)(1)(A). The government does not dispute that Fowle has exhausted his

administrative remedies and has health conditions that create extraordinary and

compelling reasons for release. See 18 U.S.C. § 3582(c)(1)(A). The government

objects to release based on the sentencing factors set forth in 18 U.S.C. § 3553(a).

The court has considered the goals of sentencing and finds that release is consistent

with § 3553(a).

COMPASSIONATE RELEASE STATUTE

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). Some courts have held that the policy

statement, U.S.S.G. § 1B1.13, is not applicable to a prisoner’s motion for

compassionate release. See United States v. Brooker, 976 F.3d 228, 234–36 (2d

Cir., 2020). The policy statement, however, provides “helpful guidance” even if

consistency with § 1B1.13 is not a strict statutory requirement. See United States

v. Dent, Crim. No. 2:15-CR-10-DBH-01, 2020 WL 6157693, at *1 (D. Me. Oct. 21,

2 2020). For example, the policy statement requires that “the defendant is not a

danger to the safety of any other person or to the community” in order to be eligible

for a sentence reduction. U.S.S.G. § 1B1.13(2). Since public protection is a

sentencing factor under § 3553(a), dangerousness is a consideration in every

compassionate release case. 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 courts consider the need to protect the public).

The defendant bears the burden of showing that he is entitled to a sentence

reduction. United States v. Hilow, No. 15-CR-170-JD, 2020 WL 2851086, *3

(D.N.H. June 2, 2020). 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).

BACKGROUND

Fowle is currently imprisoned for a violation of supervised release. Fowle’s

underlying convictions are: (1) possession with intent to distribute oxycodone and

(2) conspiracy to distribute and possession with intent to distribute marijuana. See

21 U.S.C. §§ 841(a)(1), 846. He was sentenced on September 28, 2015 to 37 months

incarceration and 3 years supervised release. He was released on February 28,

2017.

3 Since his release, Fowle has violated conditions of supervised release three

times. Fowle’s first violation was for repeatedly using marijuana and cocaine,

refusing to permit his probation officer to visit and search him, and associating with

a felon. On February 27, 2018, the court sentenced Fowle to time served (49 days)

and 24 months of supervised release.1

Fowle’s second violation was for use of marijuana and cocaine, and for failure

to report a change in employment. On January 11, 2019, the court sentenced Fowle

on that violation to 9 months incarceration and 12 months supervised release.

Fowle was released from custody on May 8, 2019.

Less than one week following his release, Fowle committed his third

violation. This is the violation for which he is currently incarcerated. During his

initial visit with his probation officer, Fowle provided a urine sample and then

destroyed it by dumping the contents of the collection cup on the ground. The court

also found that Fowle had used cocaine and marijuana since his release. The court

sentenced him on this third violation on January 16, 2020. Although the advisory

guideline range was 6 to 12 months, the court sentenced Fowle to the statutory

maximum: 24 months incarceration with no additional supervised release. Fowle

appealed this sentence to the First Circuit. See USCA no. 20-1134. That appeal is

still pending.

1 Additionally, and unrelated to these probation violations, Fowle was

arrested for DWI on July 25, 2018. He pled guilty to DWI first offense on May 28, 2020. See doc. no. 396-3. 4 For this most recent period of incarceration, Fowle has served 13 months,

more than one-half of his sentence. His projected release date is July 4, 2021.

DISCUSSION

I. Procedural History

There is no dispute that Fowle has exhausted his administrative right to

appeal within BOP and that his motion is properly before the court. Fowle filed this

motion for compassionate release while his underlying sentence was on appeal to

the First Circuit. See USCA no. 20-1134. After this court ordered him to show

cause why it had jurisdiction over his motion, Fowle moved for an indicative ruling

under Federal Rule of Criminal Procedure 37 and Federal Rule of Appellate

Procedure 12.1. See doc. no. 400; see also United States v. Pena, 463 F. Supp. 3d

118 (D. Mass.

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