United States v. Holroyd

CourtDistrict Court, District of Columbia
DecidedFebruary 12, 2021
DocketCriminal No. 2017-0234
StatusPublished

This text of United States v. Holroyd (United States v. Holroyd) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Holroyd, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Case No. 1:17-cr-00234-2 (TNM) WAYNE HOLROYD,

Defendant.

MEMORANDUM AND ORDER

Wayne Holroyd is serving a 120-month prison sentence for conspiracy to distribute and

possess with intent to distribute more than 280 grams of a mixture or substance containing a

detectable amount of cocaine base. Judgment at 1–2, ECF No. 198; see 21 U.S.C. §§ 841(a)(1),

(b)(1)(A)(iii), 846. 1 He resides at the Federal Correctional Institution (“FCI”) in Ashland,

Kentucky.

The Court has previously rejected Holroyd’s motion for compassionate release, as well as

two pro se motions for reconsideration. Before the Court is Holroyd’s third pro se motion for

reconsideration. Having reviewed Holroyd’s filings, the relevant law, and the entire record of

the case, the Court will deny this motion.

I.

The factual background of this case is well-documented elsewhere. See United States v.

Holroyd, 464 F. Supp. 3d 14, 16–17 (D.D.C. 2020) (“Holroyd I”); United States v. Holroyd, No.

17-cr-00234-2-TNM, 2020 WL 4219823, at *1–*2 (D.D.C. July 23, 2020) (“Holroyd II”). The

1 All page citations refer to the page numbers that the CM/ECF system generates. Court briefly recounts only the procedural history relevant to his pending motion for

reconsideration.

In April 2020, Holroyd moved for compassionate release under 18 U.S.C.

§ 3582(c)(1)(A)(i). Holroyd’s motion was filed pro se but supplemented by appointed

counsel. See Def.’s Mot., ECF No. 224; Def.’s Reply in Supp. of Original Mot., ECF No. 228;

Def.’s Renewed Mot., ECF No. 231. The Court denied the motion, Holroyd I, 464 F. Supp. 3d at

22, as well as Holroyd’s subsequent pro se motion for reconsideration, Holroyd II, 2020 WL

4219823, at *4. Both decisions were affirmed on appeal. 2 See United States v. Holroyd, 825

Fed. App’x 1 (D.C. Cir. 2020). Holroyd then filed a second pro se motion for reconsideration,

which the Court also denied. See 10/13/2020 Min. Order.

Two months after the denial of his second motion for reconsideration, Holroyd sent the

Court a letter stating that FCI Ashland “has contracted a large percentage of COVID-19

cases.” 12/3/2020 Letter at 1, ECF No. 257. He asserted that the facility was not taking

adequate safety precautions and that he could not protect himself. Id. Holroyd also explained

that he is “not a bad candidate for release” because he had “successfully completed parole,” “was

employed” before his arrest, had “clear conduct for 9 months prior to [his] arrest,” and is “41

years old.” Id. The Court construed the letter as a motion for compassionate release and

accordingly, ordered the Government to respond. See 12/3/2020 Min. Order.

Holroyd then sent the Court a “Letter to Withdraw,” stating that the previous letter he had

sent was an “update” on the COVID-19 outbreak at FCI Ashland rather than a motion.

1/29/2021 Letter, ECF No. 264. At the same time, he also submitted a “Memorandum for

2 The D.C. Circuit has since denied Holroyd’s petition for rehearing en banc. See Per Curiam Order, No. 20-3041 (D.C. Cir. Jan. 19, 2021).

2 Reconsideration of Compassionate Release,” which the Court construes as a motion for

reconsideration of its previous denial of Holroyd’s motion for compassionate release. Mot. for

Recons., ECF No. 265.

II.

As the Court has explained before, see Holroyd I, 464 F. Supp. 3d at 17 & n.3; Holroyd

II, 2020 WL 4219823, at *2, a court may reduce a defendant’s term of imprisonment if, “after

considering the factors set forth in [18 U.S.C. § 3553(a)] to the extent that they are

applicable, . . . it finds that . . . 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)(i). Under the Commission’s

applicable policy statement, a court may reduce a term of imprisonment “if, after considering the

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

determines that . . . (1)(A) Extraordinary and compelling reasons warrant the reduction . . . (2)

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); and (3) The reduction is consistent with this policy statement.” U.S.S.G.

§ 1B1.13.

The burden is on Holroyd to establish that he is eligible for a sentence reduction. See,

e.g., United States v. Jones, 836 F.3d 896, 899 (8th Cir. 2016) (noting that the defendant has the

burden of establishing that he is eligible for a sentence reduction under 18 U.S.C. § 3582(c)(2)).

Motions for reconsideration “permit district judges to correct their oversights and errors.”

United States v. Rollins, 607 F.3d 500, 502 (7th Cir. 2010) (citing United States v. Healy, 376

U.S. 75 (1964)). Some courts have also granted these motions “as justice requires.” United

3 States v. Hemingway, 930 F. Supp. 2d 11, 12 (D.D.C. 2013). 3 It is appropriate for a court to

deny a motion for reconsideration when it raises arguments that the court has already rejected.

Id.

III.

In his letter and motion for reconsideration, 4 Holroyd mainly argues that he should be

released based on the COVID-19 pandemic and his health conditions that put him at an increased

risk of serious illness. See 12/3/2020 Letter; Mot. for Recons. at 1–2. He also contends that he

successfully completed parole, was employed before his arrest, and had clear conduct for nine

months before his arrest. See 12/3/2020 Letter; Mot. for Recons. at 3. Holroyd also explains

that there has been a significant lapse in time since his predicate convictions, that his most recent

conviction was not for a “crime[] of violence,” and that he has “no violent history.” Mot. for

Recons. at 3–4. Nothing in Holroyd’s new filings persuades the Court to revisit its prior

decisions.

First, the Court does not doubt the serious risks posed by the COVID-19 pandemic.

Holroyd I, 464 F. Supp. 3d at 18 (“The COVID-19 pandemic has emerged as a global and

national health emergency.”). “[L]ike other judges in this District and across the country, the

Court takes notice of the real and serious threat that the COVID-19 pandemic poses.” Id. But

the Court also notes that the pandemic presents a risk that everyone is facing. And the evidence

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Healy
376 U.S. 75 (Supreme Court, 1964)
United States v. Rollins
607 F.3d 500 (Seventh Circuit, 2010)
United States v. Hemingway
930 F. Supp. 2d 11 (District of Columbia, 2013)
United States v. Edward Jones
836 F.3d 896 (Eighth Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Holroyd, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-holroyd-dcd-2021.