United States v. James Cole

CourtCourt of Appeals for the Third Circuit
DecidedMarch 26, 2024
Docket23-3105
StatusUnpublished

This text of United States v. James Cole (United States v. James Cole) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. James Cole, (3d Cir. 2024).

Opinion

DLD-074 NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 23-3105 ___________

UNITED STATES OF AMERICA

v.

JAMES COLE, Appellant

__________________________________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Criminal No. 2-91-cr-00570-002) District Judge: Honorable Paul S. Diamond ____________________________________

Submitted on Appellee’s Motion for Summary Action Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6 February 22, 2024

Before: JORDAN, PORTER, and PHIPPS, Circuit Judges

(Opinion filed: March 26, 2024) _________

OPINION * _________

PER CURIAM

James Cole, a federal prisoner proceeding pro se, appeals from the District Court’s

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. orders denying his motion to reduce his sentence pursuant to 18 U.S.C. § 3582(c)(1)(A)

and his motion to reconsider that ruling. The Government moves for summary

affirmance. We grant the Government’s motion and will summarily affirm.

In 1993, Cole was convicted of conspiring to distribute, and to possess with the

intent to distribute, heroin and cocaine, in violation of 21 U.S.C. § 846; engaging in a

continuing criminal enterprise (“CCE”), in violation of 21 U.S.C. § 848; and possessing

cocaine with intent to distribute, in violation of 21 U.S.C. § 841(a)(1). The convictions

arose from Cole’s leadership role in a largescale, violent drug trafficking operation in the

Philadelphia area. He was sentenced to a term of life imprisonment. Cole was

unsuccessful on direct appeal and in various post-judgment proceedings.

At issue here is Cole’s most recent motion to reduce his sentence pursuant to

§ 3582(c)(1)(A). 1 In the motion, he sought early release from his life sentence on the

ground that he now meets the age and sentence requirements of § 3582(c)(1)(A)(ii)

because he is seventy years old and has served thirty years in custody. Cole alternatively

sought early release under § 3582(c)(1)(A)(i) because, he argued, his age, medical

1 This was Cole’s third motion for “compassionate release” in recent years. In September 2020, he sought compassionate release under § 3582(c)(1)(A)(i) on the grounds that his age and medical conditions placed him at heightened risk of serious illness if he were to contract COVID-19. The District Court denied the motion, concluding that even if these factors constituted “extraordinary and compelling reasons” under § 3582(c)(1)(A)(i), the sentencing concerns set forth in 18 U.S.C. § 3553(a) counseled against release. In December 2022, Cole filed another motion for compassionate release based on his medical conditions. The District Court again denied relief, explaining that nothing material had changed since his last motion, and that the § 3553(a) factors still outweighed the risks posed by his medical conditions.

2 conditions (arthritis and diabetes), rehabilitative efforts, and time already spent in custody

constitute “extraordinary and compelling reasons” warranting release. The District Court

denied the motion, explaining that (1) § 3582(c)(1)(A)(ii) does not apply to him; and (2)

even if his age, medical conditions, and rehabilitative efforts constituted “extraordinary

and compelling reasons” under § 3582(c)(1)(A)(i), the sentencing concerns set forth in 18

U.S.C. § 3553(a) counseled against release. Cole moved for reconsideration, but the

District Court denied relief. He appealed. 2

The “compassionate release” provision of 18 U.S.C. § 3582 allows a district court

to reduce a prisoner’s sentence if “extraordinary and compelling reasons warrant such a

reduction,” § 3582(c)(1)(A)(i), or, alternatively, the prisoner meets the age and sentence

demands of § 3582(c)(1)(A)(ii). Before granting compassionate release, a district court

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

applicable.” Id. § 3582(c)(1)(A). Those factors include “the nature and circumstances of

the offense and the history and characteristics of the defendant,” id. § 3553(a)(1), as well

as the need for the sentence “to reflect the seriousness of the offense, to promote respect

for the law, . . . to provide just punishment for the offense,” “to afford adequate

2 We have jurisdiction under 28 U.S.C. § 1291 to review both the District Court’s order denying Cole’s § 3582(c)(1)(A) motion and its order denying reconsideration thereof. Although the Federal Rules of Criminal Procedure do not expressly authorize the filing of a motion for reconsideration in a criminal matter, the Supreme Court has held that the timely filing of such a motion tolls the time for filing a notice of appeal. See United States v. Dieter, 429 U.S. 6, 8–9 (1976); United States v. Vicaria, 963 F.2d 1412, 1413– 14 (11th Cir. 1992) (per curiam). We review both orders for an abuse of discretion. See United States v. Pawlowski, 967 F.3d 327, 330 (3d Cir. 2020); United States v. Dupree, 617 F.3d 724, 732 (3d Cir. 2010). 3 deterrence to criminal conduct,” and “to protect the public from further crimes of the

defendant,” id. § 3553(a)(2)(A)–(C).

The District Court acted well within its discretion in denying Cole’s

§ 3582(c)(1)(A) motion. First, the District Court correctly concluded that Cole was not

eligible for relief under § 3582(c)(1)(A)(ii) because that provision applies only to

prisoners who had been sentenced under 18 U.S.C. § 3559(c), the “three strikes”

provision. See 18 U.S.C. § 3582(c)(1)(A)(ii) (stating that the district court may modify a

prison term if, among other things, the defendant has served at least 30 years of a

sentence imposed under section 3559(c)). Second, the District Court reasonably

concluded that release was not warranted under § 3582(c)(1)(A)(i) in light of the §

3553(a) factors. As the District Court explained, given Cole’s leadership role in a

notoriously violent criminal enterprise, early release from his life sentence would not

protect the safety of the community, see § 3553(a)(2)(C), or reflect the seriousness of the

underlying crimes, see § 3553(a)(2)(A).

The District Court also acted within its discretion in denying Cole’s motions for

reconsideration. Although Cole argued that the District Court had not sufficiently

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

Related

United States v. Dieter
429 U.S. 6 (Supreme Court, 1976)
United States v. Dupree
617 F.3d 724 (Third Circuit, 2010)
Murray v. Bledsoe
650 F.3d 246 (Third Circuit, 2011)
United States v. Carlos C. Vicaria, M.D.
963 F.2d 1412 (Eleventh Circuit, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. James Cole, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-james-cole-ca3-2024.