United States v. Sali

CourtCourt of Appeals for the Tenth Circuit
DecidedApril 11, 2025
Docket24-8030
StatusUnpublished

This text of United States v. Sali (United States v. Sali) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Sali, (10th Cir. 2025).

Opinion

Appellate Case: 24-8030 Document: 33-1 Date Filed: 04/11/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT April 11, 2025 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-8030 (D.C. No. 2:06-CR-00084-ABJ-4) JAMES SCOTT SALI, (D. Wyo.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT* _________________________________

Before MORITZ, EID, and FEDERICO, Circuit Judges. _________________________________

James Scott Sali, a federal prisoner appearing pro se, appeals the district

court’s denial of his motion for compassionate release under 18 U.S.C.

§ 3582(c)(1)(A). Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

I. Background

In 2007, Sali pled guilty to four drug-trafficking and firearms counts and was

sentenced to 60 years in prison. In 2023, he filed a pro se motion for a sentence

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-8030 Document: 33-1 Date Filed: 04/11/2025 Page: 2

reduction under 18 U.S.C. § 3582(c)(1)(A). As relevant here, the statute provides

that, on motion, a district court “may reduce the term of imprisonment . . . after

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

applicable,” but only “if 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.” § 3582(c)(1)(A)(i). In his

motion, Sali argued that multiple health issues and what he characterized as an

unusually long sentence, allegedly due to a 15-year sentencing disparity resulting

from stacking his two firearms convictions under 18 U.S.C. § 924(c), constituted

extraordinary and compelling reasons to reduce his sentence. He also argued that he

was not going to reoffend and that the § 3553(a) factors weighed in favor of granting

a sentence reduction.

The district court denied the motion. The court assumed that Sali’s medical

circumstances and the alleged sentencing disparity amounted to extraordinary and

compelling circumstances that warranted a sentence reduction. But the court found

that a sentence reduction would be inconsistent with the Sentencing Commission’s

policy statement that a defendant not pose “a danger to the safety of any other person

or to the community, as provided in 18 U.S.C. § 3142(g),” USSG 1B1.13(a)(2).

Among other things, § 3142(g) requires a court to determine whether community

safety would be “reasonably assure[d]” if a defendant is released, taking into account

“(1) the nature and circumstances of the offense charged”; “(2) the weight of the

evidence against the person”; “(3) the history and characteristics of the person”; and

2 Appellate Case: 24-8030 Document: 33-1 Date Filed: 04/11/2025 Page: 3

“(4) the nature and seriousness of the danger to any person or the community that

would be posed by the person’s release.” § 3142(g)(1)–(4).

Applying the § 3142(g) factors, the district court found that Sali’s “storied

history of violent conduct prior to incarceration creates a strong presumption that he

would pose a danger to the safety of another person or to the community.” R. vol. I

at 126. The court noted that his conduct in this case was “undisputedly dangerous”

because it involved “large amounts of methamphetamine, the related use and

deployment of firearms, and his involvement in a scheme to murder a co-conspirator

he suspected was a police informant.” Id. at 127. The court found that his history of

twelve other convictions, including battery, multiple assaults, carrying a concealed

weapon and threatening to behead the victim, and terroristic threats/assaultive

conduct, “serve[d] to generate further caution.” Id. The court rejected Sali’s

contention that since his imprisonment, he was “a changed man,” finding that despite

his claims that he was “staying off drugs” and “learn[ing] how to kick destructive

habits,” Sali had received “a bevy of citations . . . during his incarceration.” Id.

(internal quotation marks omitted). Those included citations for “medication abuse

as late as 2021 and three infractions for disruptive behavior as late as 2022.” Id.

at 128. This conduct, the court said, was too recent for Sali “to be given the benefit

of the doubt.” Id. The court further found that Sali did “not appear to have any

sufficient vocational skills to maintain a stable career after incarceration,” and

therefore he “would continue his propensity for violent and disruptive behavior, with

3 Appellate Case: 24-8030 Document: 33-1 Date Filed: 04/11/2025 Page: 4

no impediment to dissuade him [from] criminal activity.” Id. For these reasons, the

court denied his motion. The court did not reach the § 3553(a) factors. Sali appeals.1

II. Standard of review

We review a district court’s order denying a motion for a § 3582(c)(1)(A)

sentence reduction for an abuse of discretion. See United States v. Bradley, 97 F.4th

1214, 1218 (10th Cir. 2024). “A district court abuses its discretion when it relies on

an incorrect conclusion of law or a clearly erroneous finding of fact.” Id. (internal

quotation marks omitted). A district court also abuses its discretion “when it makes a

clear error of judgment, exceeds the bounds of permissible choice, or when its

decision is arbitrary, capricious or whimsical, or results in a manifestly unreasonable

judgment.” United States v. Mobley, 971 F.3d 1187, 1195 (10th Cir. 2020) (internal

quotation marks omitted). Because Sali represents himself, we afford his pro se

filings a liberal construction, but we may not act as his advocate. See Yang v.

Archuleta, 525 F.3d 925, 927 n.1 (10th Cir. 2008).

III. Discussion

“Federal courts are forbidden, as a general matter, to modify a term of

imprisonment once it has been imposed, but the rule of finality is subject to a few

narrow exceptions.” Bradley, 97 F.4th at 1217 (internal quotation marks omitted).

1 Sali filed his notice of appeal while a motion for reconsideration he had filed was still pending.

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Related

Yang v. Archuleta
525 F.3d 925 (Tenth Circuit, 2008)
Prager v. Campbell County Memorial Hospital
731 F.3d 1046 (Tenth Circuit, 2013)
United States v. Mobley
971 F.3d 1187 (Tenth Circuit, 2020)
United States v. McGee
992 F.3d 1035 (Tenth Circuit, 2021)

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