United States of America v. P Nicholas J. Patten

560 F. Supp. 3d 613, 2021 DNH 022
CourtDistrict Court, D. New Hampshire
DecidedJanuary 27, 2021
Docket18-cr-073-LM-1
StatusPublished

This text of 560 F. Supp. 3d 613 (United States of America v. P Nicholas J. Patten) 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 Nicholas J. Patten, 560 F. Supp. 3d 613, 2021 DNH 022 (D.N.H. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 18-cr-073-LM-1 Opinion No. 2021 DNH 022 P Nicholas J. Patten

ORDER

The defendant, Nicholas J. Patten, moves for compassionate release under 18

U.S.C. § 3582(c)(1)(A) based on the combination of his underlying medical

conditions and the possibility that he will become infected with COVID-19 while

imprisoned at Federal Correctional Institute (“FCI”) Allenwood-Low in

Pennsylvania. See doc. no. 22. The government concedes that Mr. Patten has

exhausted his administrative remedies and that there are extraordinary and

compelling reasons for release, but nevertheless objects based on the sentencing

factors. The court held a video hearing on Mr. Patten’s motion on January 12, 2021,

at which Mr. Patten appeared via telephone and made a statement. After careful

consideration and for the reasons that follow, the court grants Mr. Patten’s motion.

STANDARD OF REVIEW

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

U.S.C. § 3582(c)(1)(A). This statute imposes several requirements for granting a

defendant’s motion for compassionate release. First, the defendant must either fully exhaust his administrative remedies within the Bureau of Prisons (“BOP”) or

wait thirty days after BOP receives his request to file a compassionate release

motion on his behalf. See 18 U.S.C. § 3582(c)(1)(A). Second, there must be

“extraordinary and compelling reasons” for a sentence reduction. § 3582(c)(1)(A)(i).

Third, the court must “consider[ ] the factors set forth in section 3553(a) to the

extent they are applicable.” Id. Finally, a sentence reduction must be “consistent

with applicable policy statements issued by the Sentencing Commission.” Id.; see

also U.S.S.G. § 1B1.13 (sentencing guidelines policy statement on compassionate

release).

The Sentencing Commission’s policy statement on compassionate release

largely mirrors the statutory language and adds the requirement that the

defendant be unlikely to pose a danger to the safety of any other person or the

community as provided in 18 U.S.C. § 3142(g). See U.S.S.G. § 1B1.13(2). However,

the policy statement has not been updated since enactment of the First Step Act,

which amended 18 U.S.C. § 3582(c)(1)(A) to allow defendants, rather than BOP

alone, to petition the court for compassionate release. See United States v. Brooker,

976 F.3d 228, 231-34, 236 (2d Cir. 2020) (holding that the policy statement does not

apply to motions for compassionate release brought by defendants). Even absent

the policy statement, however, a defendant’s dangerousness is a paramount concern

under § 3553(a), which the court is required to consider in every compassionate

release case. See 18 U.S.C. § 3582(c)(1)(A); 18 U.S.C. § 3553(a)(1), (2)(C) (court

must consider “the nature and circumstances of the defendant’s offense,” the

2 defendant’s “history and characteristics,” and the need “to protect the public from

further crimes of the defendant”); United States v. Bradshaw, No. 1:15-CR-422,

2019 WL 7605447, at *3 (M.D.N.C. Sept. 12, 2019) (noting overlap between policy

statement’s dangerousness requirement and analysis of § 3553(a) factors).

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

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

(D.N.H. June 2, 2020). “And the court has broad discretion in deciding whether to

grant or deny a motion for a sentence reduction.” United States v. Britton, No. 18-

CR-108-LM, 2020 WL 2404969, at *2 (D.N.H. May 12, 2020) (quotation omitted).

BACKGROUND

The grand jury indicted Mr. Patten on these charges on May 16, 2018, and a

warrant for his arrest issued that same day. Mr. Patten was arrested pursuant to

that warrant on September 5, 2018. He has been in custody since that time. On

January 29, 2019, Mr. Patten pled guilty pursuant to a plea agreement on one count

of possession with intent to distribute a controlled substance and one count of

possession of a firearm and ammunition by an unlawful user of a controlled

substance. See 21 U.S.C. § 841(a)(1); 18 U.S.C. § 922(g)(3). The parties’ plea

agreement contained a stipulation to a 48-month sentence under Federal Rule of

Criminal Procedure 11(c)(1)(C). On May 29, 2019, the court sentenced Mr. Patten

to a 48-month term of imprisonment and a three-year period of supervised release.

The court also recommended to BOP that Mr. Patten participate in BOP’s intensive

3 drug education and treatment program while incarcerated. Mr. Patten has served

more than one-half of his 4-year sentence. On December 17, 2020, Mr. Patten filed

the instant motion for compassionate release.

DISCUSSION

Mr. Patten has exhausted his administrative remedies. The BOP denied

Patten’s request for a reduction in sentence (doc. no. 22-1), so his motion is properly

before the court. Thus, to determine whether Mr. Patten is eligible for a sentence

reduction, the court must consider: (1) whether there are extraordinary and

compelling reasons for a sentence reduction; and (2) applicable sentencing factors

under § 3553(a). See 18 U.S.C. § 3582(c)(1)(A).

I. Extraordinary and Compelling Reasons

Mr. Patten contends that he has several medical conditions that put him at a

high risk for experiencing severe illness should he contract COVID-19. The

government concedes that Mr. Patten’s medical conditions meet the “extraordinary

and compelling” prong of the test for early release.

Specifically, Mr. Patten has Hepatitis C, chronic elevation of liver enzymes

suggesting a diagnosis of nonalcoholic fatty liver disease, a “mildly heterogeneous”

liver, and hyperlipidemia (more commonly known as high cholesterol). Doc. no. 22

at 4-5. He also states that, as of September 9, 2019, his body mass index (BMI) was

28.7. Mr. Patten argues that these conditions, combined with the known presence

4 of COVID-19 at FCI Allenwood-Low, constitute extraordinary and compelling

reasons for a sentence reduction.

In the context of the current pandemic, courts have held that a generalized

risk of infection by the virus is not, by itself, sufficient to constitute an

extraordinary and compelling reason for release. See United States v. Ramirez, 459

F. Supp. 3d 333, 337-38 (D. Mass. 2020) (collecting cases). “On the other hand, a

combination of health and age factors that put a prisoner at a substantially higher

risk due to COVID-19 along with a documented risk of the disease in the facility

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560 F. Supp. 3d 613, 2021 DNH 022, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-p-nicholas-j-patten-nhd-2021.