United States of America v. Stephen Marando

2020 DNH 144
CourtDistrict Court, D. New Hampshire
DecidedAugust 17, 2020
Docket17-cr-163-JD
StatusPublished

This text of 2020 DNH 144 (United States of America v. Stephen Marando) 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. Stephen Marando, 2020 DNH 144 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 17-cr-163-JD-03 Opinion No. 2020 DNH 144 Stephen Marando

O R D E R

Stephan Marando moves for a reduction of his sentence

pursuant to 18 U.S.C. § 3582(c)(1)(A) and, in the alternative,

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

that he be permitted to serve the maximum amount of his sentence

in home confinement under 18 U.S.C. § 3624. In support, he

contends that he has a heightened risk of severe illness or

death if he were to contract COVID-19. The government objects

to a reduction in Marando’s sentence and to a recommendation for

release to home confinement. A United States Probation Officer

filed a report on June 24, 2020, in response to Marando’s

previous motion under § 3582(c)(1)(A), and that report has also

been considered for purposes of the pending motion.

I. Background

Marando pleaded guilty on July 24, 2018, to charges of

conspiracy to possess with intent to distribute forty grams or

more of fentanyl and possession with intent to distribute forty grams or more fentanyl. On March 14, 2019, he was sentenced to

sixty-six months of incarceration to be followed by five years

of supervised release. His projected release date is August 5,

2022, and he has served not quite half of his sentence. He is

serving his sentence at the Federal Correctional Institute in

Allenwood, Pennsylvania (“FCI Allenwood”) in medium security.

Marando is fifty-nine years old. He has a variety of

medical conditions and issues, including hypertension, Hepatitis

C, degenerative disc disease, and anemia. Despite his medical

issues he has no medical restrictions except that he requires a

lower bunk.

FCI Allenwood was not reporting any active cases at the

time when Marando filed his motion. Counsel, on Marando’s

behalf, suggests that the lack of reported cases may be because

there is insufficient testing. The government also represented

that there were no inmates or staff at FCI Allenwood with COVID-

19 as of early August.

During his period of incarceration, Marando has not had any

disciplinary reports. On the other hand, he has not

participated in either the drug education program or the

residential drug abuse treatment program. He has been assessed

to have a high risk of recidivism. In addition, the probation

officer reported that Marando has a number of outstanding

warrants that could affect any planned release.

2 On April 30, 2020, Marando submitted a request to the

warden to serve the remainder of his sentence in home

confinement.1 That request was denied. He then filed a pro se

motion with the court, which was denied because he had not

exhausted administrative remedies. Marando filed a pro se

request under § 3582(c)(1)(A) with the warden on June 26, 2020.

That request was denied on July 8, 2020.

II. Request for Reduced Sentence

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

defendant to reduce the term of his or her imprisonment.

§ 3582(c)(1)(A). If the Director does not file a motion, 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 Bureau of

Prisons 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 request. 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

1His requests apparently combined requests for release to home confinement under § 3624 with requests for a reduction in sentence under § 3582(c)(1)(A).

3 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

§ 3582(c)(1)(A).2 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, 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

2 The Sentencing Commission has not been able to amend § 1B1.13 to conform to the statutory changes made by the First Step Act because the Commission lacks a quorum. United States v. Greene, 2020 WL 4475892, at *3, n.1 (D. Me. Aug. 4, 2020).

4 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.”

In summary, to be eligible for a reduction in sentence

under § 3582(c)(1)(A), a defendant must first exhaust

administrative remedies. If that is accomplished, a defendant

must show that he has an extraordinary and compelling reason

that justifies a reduction in his sentence, considering the

sentencing factors under § 3553(a) and the policy statement.

A. Initial Considerations

The government agrees that Marando has satisfied the

requirement of administrative exhaustion and that he has shown

an extraordinary and compelling reason for sentence reduction,

based on his health conditions in combination with the risks due

to COVID-19. The court will accept the agreement on those

issues.

B. Sentencing Factors under § 3553(a)

Section 3553(a) states that the “court shall impose a

sentence sufficient, but not greater than necessary, to comply

with the purposes” provided in § 3553(a)(2), and lists factors

for determining an appropriate sentence. The first two factors

5 are particularly pertinent here.3 The first factor directs the

sentencing court to consider “the nature and circumstances of

the offense and the history and characteristics of the

defendant.” § 3553(a)(1). The second factor focuses on the

purposes of sentencing, including:

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Related

Release of a prisoner
18 U.S.C. § 3624

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2020 DNH 144, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-stephen-marando-nhd-2020.