United States v. Edwin Culp

CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 20, 2023
Docket22-1166
StatusUnpublished

This text of United States v. Edwin Culp (United States v. Edwin Culp) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Edwin Culp, (6th Cir. 2023).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 23a0408n.06

No. 22-1166 FILED UNITED STATES COURT OF APPEALS Sep 20, 2023 FOR THE SIXTH CIRCUIT DEBORAH S. HUNT, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE EASTERN DISTRICT OF EDWIN CULP, ) MICHIGAN Defendant-Appellant. ) ) OPINION

Before: BATCHELDER, GRIFFIN, and LARSEN, Circuit Judges.

PER CURIAM. Edwin Culp appeals the district court’s order denying his motion for

reconsideration of its prior denial of compassionate release under 18 U.S.C. § 3582(c)(1)(A). As

set forth below, we AFFIRM the district court’s order.

In 1995, Culp pleaded guilty to conspiracy to possess with intent to distribute and to

distribute cocaine, in violation of 21 U.S.C. §§ 841(a)(1) and 846. Culp failed to appear for his

sentencing. After his apprehension a year later, the district court sentenced Culp to 121 months of

imprisonment. A federal grand jury subsequently charged Culp in a supplemental indictment with

three counts of murder in furtherance of a continuing criminal enterprise, in violation of 21 U.S.C.

§ 848(e)(1)(A), and three counts of using and carrying a firearm during and in relation to a drug

trafficking crime, in violation of 18 U.S.C. § 924(c). Following a jury trial, Culp was convicted

on one murder count and the related firearm count and acquitted on the other counts. The district

court sentenced Culp to life imprisonment. On direct appeal, we affirmed Culp’s conviction. No. 22-1166, United States v. Culp

United States v. Sellers, 9 F. App’x 335 (6th Cir. 2001). Culp is currently 51 years old and confined

at FCI Pekin. See Find an Inmate, Federal Bureau of Prisons, https://www.bop.gov/inmateloc (last

visited Sept. 19, 2023).

In February 2021, Culp filed a pro se motion for compassionate release under 18 U.S.C.

§ 3582(c)(1)(A). The district court appointed counsel, who filed a supplemental brief. Culp’s

motion, as supplemented, asserted that he faced an increased risk of severe illness or death from

COVID-19 based on his age; African-American race; and medical conditions, including obesity,

chronic kidney disease, high blood pressure, hypertension, and sarcoidosis. Culp further argued

that the district court should consider other factors in conjunction with his medical conditions as

grounds supporting compassionate release: he received a life sentence under the mandatory

sentencing guidelines prior to the Supreme Court’s decision in United States v. Booker, 543 U.S.

220 (2005), which made the guidelines advisory; he was a relatively youthful offender acting at

the direction of his co-defendants; and his older and more culpable co-defendants received more

lenient sentences and had since been released from prison.

The district court denied Culp’s motion for compassionate release. The district court first

determined that Culp’s claimed vulnerability to COVID-19 did not amount to an extraordinary and

compelling reason warranting his release, noting that he had been offered the COVID-19 vaccine

and refused it and that he had contracted COVID-19 and not suffered significant effects. Based

on United States v. Hunter, 12 F.4th 555 (6th Cir. 2021), a case involving one of Culp’s co-

defendants, the district court declined to consider the facts that existed at the time of his sentencing

as extraordinary and compelling reasons for his release. See id. at 569. The district court also

found that the sentencing factors under 18 U.S.C. § 3553(a) did not support Culp’s release.

-2- No. 22-1166, United States v. Culp

Culp then moved for reconsideration based on United States v. McCall, 20 F.4th 1108

(6th Cir. 2021), which held that a district court may consider a nonretroactive change in sentencing

law in combination with other factors to determine whether a defendant has established

extraordinary and compelling reasons for compassionate release. Culp asked the district court to

reconsider its order denying compassionate release to address his medical conditions in

combination with “the non-retroactive change in the sentencing law (i.e., Booker), his relative

youth at the time of the offense and lesser culpability, and the sentencing disparity caused by the

confluence of these factors.”

The district court denied Culp’s motion for reconsideration. The district court concluded

that McCall did not compel reconsideration of its order denying compassionate release, noting the

intra-circuit split as to whether a district court could consider a nonretroactive change in the law

in combination with other factors to determine whether a defendant’s circumstances are

extraordinary and compelling. The district court went on to point out that it had also denied

compassionate release on the basis that the § 3553(a) factors did not weigh in favor of

compassionate release and that McCall did not affect that part of its ruling.

Culp timely appealed the district court’s order denying his motion for reconsideration.

After Culp filed this appeal, we granted rehearing en banc in McCall and vacated our prior

decision. United States v. McCall, 29 F.4th 816 (6th Cir. 2022) (mem.). We have since issued the

en banc decision. United States v. McCall, 56 F.4th 1048 (6th Cir. 2022) (en banc).

We review the district court’s denial of compassionate release under § 3582(c)(1)(A) for

an abuse of discretion. United States v. Ruffin, 978 F.3d 1000, 1005 (6th Cir. 2020). “An abuse

of discretion occurs when the district court ‘relies on clearly erroneous findings of fact, uses an

-3- No. 22-1166, United States v. Culp

erroneous legal standard, or improperly applies the law.’” United States v. Elias, 984 F.3d 516,

520 (6th Cir. 2021) (quoting United States v. Flowers, 963 F.3d 492, 497 (6th Cir. 2020)).

The compassionate-release statute authorizes the district court to reduce a defendant’s

sentence if it finds that (1) “extraordinary and compelling reasons warrant such a reduction,”

(2) the “reduction is consistent with applicable policy statements issued by the Sentencing

Commission,” and (3) the § 3553(a) factors, to the extent that they apply, support the reduction.

18 U.S.C. § 3582(c)(1)(A); see Ruffin, 978 F.3d at 1004-05. The Sentencing Commission has only

recently proposed a policy statement addressing compassionate-release motions brought by

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Related

United States v. Booker
543 U.S. 220 (Supreme Court, 2004)
Lrl Properties v. Portage Metro Housing Authority
55 F.3d 1097 (Sixth Circuit, 1995)
Island Creek Coal Co. v. Jay Wilkerson
910 F.3d 254 (Sixth Circuit, 2018)
United States v. Steven Flowers
963 F.3d 492 (Sixth Circuit, 2020)
United States v. Keith Ruffin
978 F.3d 1000 (Sixth Circuit, 2020)
United States v. Lisa Elias
984 F.3d 516 (Sixth Circuit, 2021)
United States v. Scott Sherwood
986 F.3d 951 (Sixth Circuit, 2021)
United States v. Brian Broadfield
5 F.4th 801 (Seventh Circuit, 2021)
United States v. Ronald Hunter
12 F.4th 555 (Sixth Circuit, 2021)
United States v. Michael Lemons
15 F.4th 747 (Sixth Circuit, 2021)
United States v. David McCall, Jr.
20 F.4th 1108 (Sixth Circuit, 2021)
United States v. David McCall, Jr.
29 F.4th 816 (Sixth Circuit, 2022)
United States v. Sellers
9 F. App'x 335 (Sixth Circuit, 2001)
United States v. David McCall, Jr.
56 F.4th 1048 (Sixth Circuit, 2022)

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