CLD-161 NOT PRECEDENTIAL
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________
No. 25-3512 ___________
UNITED STATES OF AMERICA
v.
JAIME GONZALEZ, Appellant
____________________________________
On Appeal from the United States District Court for the District of Delaware (D.C. Criminal Action No. 1:95-cr-00052-001) District Judge: Honorable Gregory B. Williams ____________________________________
Submitted for Possible Dismissal Due to a Jurisdictional Defect or Summary Action Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6
July 9, 2026 Before: BIBAS, PHIPPS, and NYGAARD, Circuit Judges
(Opinion filed: July 20, 2026) _________
OPINION* _________
PER CURIAM
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Appellant Jaime Gonzalez, a federal prisoner proceeding pro se, appeals the
District Court’s denial of his motion for compassionate release filed pursuant to 18
U.S.C. § 3582. We will summarily affirm.
In 1995, Gonzalez was tried and convicted on charges of interstate transportation
of an explosive device, 18 U.S.C. § 844(d)(2), and traveling in interstate commerce with
intent to promote the Delaware state offense of arson, 18 U.S.C. § 1952. See United
States v. Gonzalez, 938 F. Supp. 1199, 1201 (D. Del. 1996). He was sentenced to life in
prison on the first count, and a concurrent term of five years’ imprisonment on the latter
count. He unsuccessfully challenged his conviction and sentence on direct appeal, see
United States v. Gonzalez, 127 F.3d 1097 (3d Cir. 1997) (unpublished table decision),
cert. denied, 522 U.S. 1137 (1998), and under 28 U.S.C. § 2255, see United States v.
Gonzalez, C.A. No. 20-2407 (order entered on March 4, 2021). Gonzalez also filed
multiple motions seeking to vacate or reduce his sentence. None were successful.
In 2022, Gonzalez filed a motion for compassionate release. The Government filed
a brief in opposition, and Gonzalez moved twice to supplement his motion with medical
records. The District Court granted Gonzalez’s motions to supplement but denied his
motion for compassionate release on the grounds that his medical conditions do not
present extraordinary and compelling reasons warranting such relief, and that the factors
set out in 18 U.S.C. § 3553(a) weigh against a reduction in his sentence. Gonzalez
appealed.
2 We have jurisdiction under 28 U.S.C. § 1291.1 We review the District Court’s
decision for abuse of discretion and will not disturb that decision absent “a definite and
firm conviction that [the District Court] committed a clear error of judgment[.]” United
States v. Pawlowski, 967 F.3d 327, 330 (3d Cir. 2020). We may summarily affirm the
District Court’s decision if the appeal fails to present a substantial question. See 3d Cir.
L.A.R. 27.4; 3d Cir. I.O.P. 10.6.
The District Court did not abuse its discretion in determining that Gonzalez failed
to show “extraordinary and compelling reasons” warranting a sentence reduction. 18
U.S.C. § 3582(c)(1)(A)(i). A prisoner’s health may constitute an “extraordinary and
compelling reason,” when the prisoner is suffering from “a serious physical or medical
condition . . . that substantially diminishes [his] ability . . . to provide self-care within the
environment of a correctional facility” or requires “long-term or specialized medical care
that is not being provided.” U.S.S.G. § 1B1.13(b)(1)(B), (b)(1)(C).2 Gonzalez contends
that he suffers from “chronic hypertension, [an] enlarged prostate, and chronic silent
stroke,” and that these conditions—in combination with the risk of COVID-19—
constitute “extraordinary and compelling” circumstances. ECF 201 at 3-4. But, the
1 Since it appears that Gonzalez filed his notice of appeal within 14 days of receiving the District Court’s order, see Fed. R. App. P. 4(b); United States v. Grana, 864 F.2d 312, 313 (3d Cir. 1989), and the Government agrees that the appeal is timely, see Gov’t of V.I. v. Martinez, 620 F.3d 321, 328-29 (3d Cir. 2010) (explaining that Rule 4(b)’s time limit is not jurisdictional); we resolve the appeal on the merits. 2 Although the Sentencing Commission’s interpretation is “not binding on prisoner- initiated motions” for compassionate release, it “sheds light on the meaning of extraordinary and compelling” and thus “guide[s] discretion[.]” United States v. Andrews, 12 F.4th 255, 260 (3d Cir. 2021). 3 District Court explained, Gonzalez’s medical records showed that he “is active, exercises,
and receives regular medical care for his conditions,” ECF 213 at 11, which “do not
seriously impact his activities of daily living or his self-care.” Id. at 13; see, e.g., ECF
204 at 4 (prison medical records from August 2022 stating that Gonzalez described
himself as “very active” and reported exercising “almost every day without problems”).
And, though his conditions may put him at a higher risk of serious illness from COVID-
19, the District Court reasonably determined that Gonzalez’s refusal to receive the
vaccine, belied his contention that extraordinary and compelling reasons justify his
release. See United States v. Broadfield, 5 F.4th 801, 803 (7th Cir. 2021) (reasoning that
“a prisoner who remains at elevated risk because he has declined to be vaccinated cannot
plausibly characterize that risk as an ‘extraordinary and compelling’ justification for
release”); see also United States v. Raia, 954 F.3d 594, 597 (3d Cir. 2020) (“The mere
existence of [a disease like] COVID-19 in society and the possibility that it may spread to
a particular prison alone cannot independently justify release.”). We also agree that
Gonzalez’s contention that “his post-conviction behavior, in and of itself, demonstrates
extraordinary and compelling reasons warranting consideration for a sentence reduction,”
ECF 201 at 11, is unpersuasive. See United States v. Stewart, 86 F.4th 532, 536 (3d Cir.
2023) (explaining that “rehabilitation cannot ‘by itself’ serve as an extraordinary and
compelling reason”).
Moreover, even assuming that Gonzalez could show extraordinary and compelling
reasons that would warrant a reduction under § 3582(c)(1), we discern no abuse of
discretion in the District Court’s conclusion that the § 3553(a) factors did not support
4 release. The District Court reasonably concluded that several factors—including the
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CLD-161 NOT PRECEDENTIAL
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________
No. 25-3512 ___________
UNITED STATES OF AMERICA
v.
JAIME GONZALEZ, Appellant
____________________________________
On Appeal from the United States District Court for the District of Delaware (D.C. Criminal Action No. 1:95-cr-00052-001) District Judge: Honorable Gregory B. Williams ____________________________________
Submitted for Possible Dismissal Due to a Jurisdictional Defect or Summary Action Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6
July 9, 2026 Before: BIBAS, PHIPPS, and NYGAARD, Circuit Judges
(Opinion filed: July 20, 2026) _________
OPINION* _________
PER CURIAM
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Appellant Jaime Gonzalez, a federal prisoner proceeding pro se, appeals the
District Court’s denial of his motion for compassionate release filed pursuant to 18
U.S.C. § 3582. We will summarily affirm.
In 1995, Gonzalez was tried and convicted on charges of interstate transportation
of an explosive device, 18 U.S.C. § 844(d)(2), and traveling in interstate commerce with
intent to promote the Delaware state offense of arson, 18 U.S.C. § 1952. See United
States v. Gonzalez, 938 F. Supp. 1199, 1201 (D. Del. 1996). He was sentenced to life in
prison on the first count, and a concurrent term of five years’ imprisonment on the latter
count. He unsuccessfully challenged his conviction and sentence on direct appeal, see
United States v. Gonzalez, 127 F.3d 1097 (3d Cir. 1997) (unpublished table decision),
cert. denied, 522 U.S. 1137 (1998), and under 28 U.S.C. § 2255, see United States v.
Gonzalez, C.A. No. 20-2407 (order entered on March 4, 2021). Gonzalez also filed
multiple motions seeking to vacate or reduce his sentence. None were successful.
In 2022, Gonzalez filed a motion for compassionate release. The Government filed
a brief in opposition, and Gonzalez moved twice to supplement his motion with medical
records. The District Court granted Gonzalez’s motions to supplement but denied his
motion for compassionate release on the grounds that his medical conditions do not
present extraordinary and compelling reasons warranting such relief, and that the factors
set out in 18 U.S.C. § 3553(a) weigh against a reduction in his sentence. Gonzalez
appealed.
2 We have jurisdiction under 28 U.S.C. § 1291.1 We review the District Court’s
decision for abuse of discretion and will not disturb that decision absent “a definite and
firm conviction that [the District Court] committed a clear error of judgment[.]” United
States v. Pawlowski, 967 F.3d 327, 330 (3d Cir. 2020). We may summarily affirm the
District Court’s decision if the appeal fails to present a substantial question. See 3d Cir.
L.A.R. 27.4; 3d Cir. I.O.P. 10.6.
The District Court did not abuse its discretion in determining that Gonzalez failed
to show “extraordinary and compelling reasons” warranting a sentence reduction. 18
U.S.C. § 3582(c)(1)(A)(i). A prisoner’s health may constitute an “extraordinary and
compelling reason,” when the prisoner is suffering from “a serious physical or medical
condition . . . that substantially diminishes [his] ability . . . to provide self-care within the
environment of a correctional facility” or requires “long-term or specialized medical care
that is not being provided.” U.S.S.G. § 1B1.13(b)(1)(B), (b)(1)(C).2 Gonzalez contends
that he suffers from “chronic hypertension, [an] enlarged prostate, and chronic silent
stroke,” and that these conditions—in combination with the risk of COVID-19—
constitute “extraordinary and compelling” circumstances. ECF 201 at 3-4. But, the
1 Since it appears that Gonzalez filed his notice of appeal within 14 days of receiving the District Court’s order, see Fed. R. App. P. 4(b); United States v. Grana, 864 F.2d 312, 313 (3d Cir. 1989), and the Government agrees that the appeal is timely, see Gov’t of V.I. v. Martinez, 620 F.3d 321, 328-29 (3d Cir. 2010) (explaining that Rule 4(b)’s time limit is not jurisdictional); we resolve the appeal on the merits. 2 Although the Sentencing Commission’s interpretation is “not binding on prisoner- initiated motions” for compassionate release, it “sheds light on the meaning of extraordinary and compelling” and thus “guide[s] discretion[.]” United States v. Andrews, 12 F.4th 255, 260 (3d Cir. 2021). 3 District Court explained, Gonzalez’s medical records showed that he “is active, exercises,
and receives regular medical care for his conditions,” ECF 213 at 11, which “do not
seriously impact his activities of daily living or his self-care.” Id. at 13; see, e.g., ECF
204 at 4 (prison medical records from August 2022 stating that Gonzalez described
himself as “very active” and reported exercising “almost every day without problems”).
And, though his conditions may put him at a higher risk of serious illness from COVID-
19, the District Court reasonably determined that Gonzalez’s refusal to receive the
vaccine, belied his contention that extraordinary and compelling reasons justify his
release. See United States v. Broadfield, 5 F.4th 801, 803 (7th Cir. 2021) (reasoning that
“a prisoner who remains at elevated risk because he has declined to be vaccinated cannot
plausibly characterize that risk as an ‘extraordinary and compelling’ justification for
release”); see also United States v. Raia, 954 F.3d 594, 597 (3d Cir. 2020) (“The mere
existence of [a disease like] COVID-19 in society and the possibility that it may spread to
a particular prison alone cannot independently justify release.”). We also agree that
Gonzalez’s contention that “his post-conviction behavior, in and of itself, demonstrates
extraordinary and compelling reasons warranting consideration for a sentence reduction,”
ECF 201 at 11, is unpersuasive. See United States v. Stewart, 86 F.4th 532, 536 (3d Cir.
2023) (explaining that “rehabilitation cannot ‘by itself’ serve as an extraordinary and
compelling reason”).
Moreover, even assuming that Gonzalez could show extraordinary and compelling
reasons that would warrant a reduction under § 3582(c)(1), we discern no abuse of
discretion in the District Court’s conclusion that the § 3553(a) factors did not support
4 release. The District Court reasonably concluded that several factors—including the
nature and circumstances of the offense and the need for the sentence imposed to reflect
the seriousness of the offense, to afford adequate deterrence, and to promote respect for
the law—weighed against compassionate release. See 18 U.S.C. § 3553(a)(1), (2); see
also Pawlowski, 967 F.3d at 330-31 (denying motion for compassionate release
considering, inter alia, the seriousness of the defendant’s crimes and need to promote
respect for the law).
Accordingly, we will summarily affirm the judgment of the District Court.