United States v. Santos

CourtCourt of Appeals for the Second Circuit
DecidedJune 23, 2025
Docket22-3213
StatusUnpublished

This text of United States v. Santos (United States v. Santos) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second 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. Santos, (2d Cir. 2025).

Opinion

22-3213-cr United States v. Santos

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER“). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 23rd day of June, two thousand twenty-five.

PRESENT: JOSÉ A. CABRANES, RAYMOND J. LOHIER, JR., RICHARD J. SULLIVAN, Circuit Judges. ------------------------------------------------------------------ UNITED STATES OF AMERICA,

Appellee,

v. No. 22-3213-cr

RAFAEL ROMERO, ALBERT RODRIGUEZ,

Defendants,

RAFAEL SANTOS,

Defendant-Appellant. ------------------------------------------------------------------ FOR APPELLANT: Rafael Santos, pro se, White Deer, PA

FOR APPELLEE: Matthew J.C. Hellman, James Ligtenberg, Assistant United States Attorneys, for Matthew Podolsky, Acting United States Attorney for the Southern District of New York, New York, NY

Appeal from orders of the United States District Court for the Southern

District of New York (Loretta A. Preska, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the orders of the District Court are AFFIRMED.

Rafael Santos, proceeding pro se, appeals from two orders entered on

December 12, 2022 by the United States District Court for the Southern District of

New York (Preska, J.) denying his motion for compassionate release pursuant to

18 U.S.C. § 3582(c)(1)(A) and his motion for reconsideration of the District

Court’s denial of a previous motion for compassionate release. 1 We assume the

1 Although Santos’s notice of appeal specifies only that he is appealing the denial of his motion for reconsideration, Santos’s appellate brief states he is challenging the denial of his motion for compassionate release. Because a notice of appeal filed by a pro se litigant is given liberal construction, and the Government is not prejudiced, we consider both Santos’s challenges to the district court’s denial of his motion for reconsideration

2 parties’ familiarity with the underlying facts and the record of prior proceedings,

to which we refer only as necessary to explain our decision to affirm.

Following a jury trial in 1989, Santos was convicted on seven counts

stemming from his involvement in a large-scale drug trafficking conspiracy.

During a Drug Enforcement Administration (“DEA”) raid on the trafficking

operation, Santos shot DEA Special Agent Bruce Travers in the face and then also

shot a cooperating witness. Santos was sentenced principally to a term of life

imprisonment on each of one count of conspiring to distribute more than five

kilograms of cocaine, in violation of 21 U.S.C. § 846, and one count of conspiring

to murder a federal officer, in violation of 18 U.S.C. § 1117.

In the decades since this Court upheld Santos’s conviction and sentence on

direct appeal, see United States v. Romero, 897 F.2d 47, 49–54 (2d Cir. 1990), Santos

has sought various forms of relief. Relevant to this appeal, in June 2022 Santos

filed a pro se motion for compassionate release pursuant to 18 U.S.C.

§ 3582(c)(1)(A), based on his deteriorating health. The District Court denied the

and his motion for compassionate release. See Grune v. Coughlin, 913 F.2d 41, 43 (2d Cir. 1990). Based on Santos’s letter replies to this Court’s previous order of February 6, 2025, we deem the opening and reply brief to have been filed on his behalf and with his authorization. See Publicola v. Lomenzo, 54 F.4th 108, 112 (2d Cir. 2022). 3 motion on June 13, 2022, explaining that, even assuming Santos had

demonstrated extraordinary and compelling circumstances, the sentencing

factors listed in 18 U.S.C. § 3553(a) weighed heavily against release. Santos

moved for reconsideration, and, while his reconsideration motion was pending,

filed a new pro se motion for compassionate release. On December 12, 2022, the

District Court denied both motions. This appeal followed.

We review the denial of a motion for compassionate release for abuse of

discretion. See United States v. Halvon, 26 F.4th 566, 569 (2d Cir. 2022). The

compassionate-release provision authorizes a court to “reduce [a] term of

imprisonment . . . after considering the factors set forth in section 3553(a) to the

extent that they are applicable, if it finds that . . . extraordinary and compelling

reasons warrant such a reduction.” 18 U.S.C. § 3582(c)(1)(A)(i). The defendant

has the burden of showing that he is entitled to a sentence reduction. See United

States v. Jones, 17 F.4th 371, 374–75 (2d Cir. 2021). Even if a “defendant has

shown extraordinary and compelling reasons that might (in other circumstances)

justify a sentence reduction,” a court may deny a motion for compassionate

release “in sole reliance on the applicable § 3553(a) sentencing factors.” United

States v. Keitt, 21 F.4th 67, 69 (2d Cir. 2021). We similarly review the denial of a

4 motion for reconsideration for abuse of discretion. See Commerzbank AG v. U.S.

Bank, N.A., 100 F.4th 362, 376 (2d Cir. 2024). We have emphasized that the

standard for granting reconsideration “is strict, and reconsideration will

generally be denied unless the moving party can point to controlling decisions or

data that the court overlooked.” Id. at 377 (internal quotation marks omitted).

We affirm the District Court’s denial of Santos’s motions for

reconsideration and compassionate release. The District Court first denied the

motion for reconsideration after carefully assessing the § 3553(a) factors as they

applied to Santos in its initial June 2022 order. For example, the District Court

explained that it had “consider[ed] Mr. Santos’[s] purported expression of

remorse” but afforded it “little weight.” United States v. Santos, No. 88 CR 642,

2022 WL 17586420, at *2 (S.D.N.Y. Dec. 12, 2022). It likewise noted that it had

considered but discounted Santos’s claims that he no longer presented a danger

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Related

Jeffrey Grune v. Thomas A. Coughlin
913 F.2d 41 (Second Circuit, 1990)
United States v. Cavera
550 F.3d 180 (Second Circuit, 2008)
United States v. Jones
17 F.4th 371 (Second Circuit, 2021)
United States v. Keitt
21 F.4th 67 (Second Circuit, 2021)
United States v. Marlon Clenista
26 F.4th 566 (Second Circuit, 2022)
Publicola v. Lomenzo
54 F.4th 108 (Second Circuit, 2022)
Commerzbank AG v. U.S. Bank, N.A.
100 F.4th 362 (Second Circuit, 2024)

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United States v. Santos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-santos-ca2-2025.