United States v. Jeremy Sherrod

CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 1, 2021
Docket21-1281
StatusUnpublished

This text of United States v. Jeremy Sherrod (United States v. Jeremy Sherrod) 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. Jeremy Sherrod, (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0411n.06

No. 21-1281

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Sep 01, 2021 UNITED STATES OF AMERICA, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN JEREMY SHERROD, ) DISTRICT OF MICHIGAN ) Defendant-Appellant. ) )

BEFORE: SUTTON, Chief Judge; McKEAGUE and WHITE, Circuit Judges.

HELENE N. WHITE, Circuit Judge. Federal inmate Jeremy Sherrod appeals the denial

of his motion seeking compassionate release in light of his medical conditions and history, and his

risk of becoming severely ill if exposed to COVID-19. Sherrod argues that the district court abused

its discretion by determining that there were no extraordinary and compelling reasons justifying

his release based solely on the Bureau of Prisons’ (BOP) data reflecting low COVID-19 numbers

at his facility on the particular day his motion was decided. We disagree with Sherrod’s

characterization of the district court’s reasoning and AFFIRM.

I.

On June 27, 2017, a grand jury charged Sherrod with one count of Hobbs Act robbery; one

count of using, carrying, or brandishing a firearm during and in relation to the Hobbs Act robbery;

one count of being a felon in possession of a firearm; and one count of conspiracy to commit a

Hobbs Act robbery. Sherrod pleaded guilty to all four counts, and the district court imposed a

below-Guidelines sentence of 120 months’ imprisonment. No. 21-1281, United States v. Sherrod

Sherrod is currently serving his sentence at FCI McKean, a medium-security facility in

Lewis Run, Pennsylvania, that currently houses approximately 847 inmates. On January 5, 2021,

Sherrod filed a motion for compassionate release pursuant to 18 U.S.C. § 3582(c)(1)(A). Sherrod

argued that his medical conditions of obesity and prediabetes, as well as his status as a former

smoker and a person born with pneumonia, created extraordinary and compelling circumstances

warranting release by increasing his risk of complications or death from COVID-19. Sherrod

argued that “prison exacerbate[d] [his] risk[]” given the BOP’s report that FCI McKean had

twenty-six known positive cases of COVID-19 as of January 4, 2021. R. 139, PID 685 (citing

Bureau of Prisons, “COVID-19”, www.bop.gov/coronavirus/). Sherrod also argued that the 18

U.S.C. § 3553(a) sentencing factors supported his release.

The government opposed Sherrod’s motion. Although it “agree[d] that Sherrod’s

circumstances—including his heightened risk for severe complications from C[OVID]-19 based

on his obesity—qualify as ‘extraordinary and compelling reasons’ for release,” R. 145, PID 741,

it argued that his particularized concerns about contracting COVID-19 were speculative.

Specifically, the government argued that regardless of Sherrod’s obesity, BOP had implemented a

number of precautions at FCI McKean—such as vaccine distribution, targeted detainee release,

and isolation procedures—that mitigated Sherrod’s risk from COVID-19. The government also

noted that FCI McKean had only sixteen active cases of COVID-19.1 Finally, the government

argued that even if extraordinary and compelling circumstances were present, the § 3553(a) factors

counselled against Sherrod’s release.

1 Presumably this information was current as of the time of the government’s response, though the brief does not date the data or cite its source.

-2- No. 21-1281, United States v. Sherrod

In his reply brief, filed January 26, 2021, Sherrod disputed the government’s assessment

of his COVID-19 risk at FCI McKean. He cited the BOP COVID-19 website, which, as of January

25, 2021, was reporting 159 positive cases among inmates at that facility. The district court later

gave Sherrod permission to supplement the record further. On March 2, 2021, Sherrod accordingly

filed an affidavit, dated January 28, 2021, discussing his experience with the conditions of

confinement at FCI McKean.

The district court denied Sherrod’s motion on March 8, 2021, on the basis that there were

no extraordinary and compelling circumstances warranting compassionate release. The court

rejected Sherrod’s argument that his alleged prediabetes, smoking history, or infantile pneumonia

increased his medical risk from COVID-19. However, the court agreed that Sherrod’s BMI of

49.2 was “well in excess of the [Centers for Disease Control (CDC)’s] obesity threshold of 30,

which the government concedes is a recognized serious medical risk factor [for susceptibility to

COVID-19].” R. 154, PID 926. The district court then concluded that there were no extraordinary

and compelling circumstances for the following reasons:

Recent reports indicate that the probability of infection at McKean, although once quite high, now is very low, with only three active cases among inmates, and no active infections among staff. The defendant has two recognized medical risk factors, but, in the absence of any active coronavirus cases among inmates at his facility, he has not sufficiently established that he presently faces an extraordinary and compelling medical risk that warrants release.2

But for his obesity, the defendant, a relatively young inmate, has no other tangible serious risk factors, and he faces at present an apparently remote probability of infection. “‘[O]n similar facts this Court has declined to order the release of otherwise healthy . . . inmates with obesity as their only cognizable risk factor, absent other indications of serious medical risk,’ particularly where they were confined at institutions with few or no active coronavirus cases.” United States v.

2 It is unclear where the references to two recognized medical risks and the absence of active cases among inmates come from. Elsewhere the district court identifies only one recognized risk—obesity—and states that there were three active cases at the facility.

-3- No. 21-1281, United States v. Sherrod

Shumaker, No. 18-20286, 2021 WL 289653, at *4 (E.D. Mich. Jan. 28, 2021) (collecting cases). “There are no distinguishing facts here that warrant a different result, particularly in light of the relatively low risk of infection.” Ibid.

Id. at 927-28.

The district court did not address the § 3553(a) sentencing factors. Sherrod filed a timely

appeal.

II.

The compassionate-release statute allows a district court to reduce an inmate’s sentence if

it (1) finds that “extraordinary and compelling reasons warrant such a reduction”; (2) finds that a

reduction is “consistent with applicable policy statements issued by the Sentencing Commission”;

and (3) “consider[s] the factors set forth in [18 U.S.C. § 3553(a)] to the extent that they are

applicable.” 18 U.S.C. § 3582(c)(1)(A)(i). Because the second requirement is not at issue where

the defendant, rather than the BOP, brings the motion for release, district courts may deny

compassionate-release motions where either the first or third requirement is lacking and do not

need to address the other. See United States v. Elias, 984 F.3d 516, 519 (6th Cir. 2021).

The statute does not define extraordinary and compelling reasons. It instead “delegat[es]

that task to the Sentencing Commission.” Id. at 518.

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