United States v. Sitzmann

CourtDistrict Court, District of Columbia
DecidedMarch 25, 2022
DocketCriminal No. 2008-0242
StatusPublished

This text of United States v. Sitzmann (United States v. Sitzmann) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Sitzmann, (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

___________________________________ ) UNITED STATES OF AMERICA ) ) v. ) ) Criminal No. 08-0242 (PLF) GREGORY JOEL SITZMANN, ) ) Defendant. ) ___________________________________ )

OPINION AND ORDER

Pending before the Court are defendant Gregory Joel Sitzmann’s pro se Request

for Reduction of Sentence (“Def. Pro Se Mot.”) [Dkt. No. 319] and his Motion for

Compassionate Release Pursuant to 18 U.S.C. § 3582(c)(1)(A)(i) (“Def. Suppl. Mot.”) [Dkt.

No. 327] filed through counsel. Mr. Sitzmann contends that his advanced age, numerous

medical conditions, and deteriorating overall health justify a sentence reduction pursuant to

18 U.S.C. § 3582(c)(1)(A)(i). Def. Pro Se Mot. at 3-4; Def. Suppl. Mot. at 1-2.

The United States opposes these motions, arguing that Mr. Sitzmann’s concerns

surrounding his health and aging do not establish extraordinary and compelling reasons for a

sentence reduction, and that Mr. Sitzmann’s offense and his criminal history weigh against

releasing him. See United States’ Opposition to Defendant’s Motion to Reduce Sentence

Pursuant to the Compassionate Release Statute (“Gov’t Opp.”) [Dkt. No. 329] at 1. The

government maintains that Mr. Sitzmann should serve out his full sentence to account for the serious nature of his offenses and because he remains a danger to the community. Id. at 1. For

the following reasons, the Court will deny Mr. Sitzmann’s motions for compassionate release. 1

I. BACKGROUND

A federal grand jury charged Mr. Sitzmann in a one count indictment filed on

August 7, 2008, with Conspiracy to Distribute and Possess with Intent to Distribute Five

Kilograms or More of Cocaine, in violation of 21 U.S.C. § 846. Indictment at 1. At the time of

the indictment, Mr. Sitzmann had served in a French prison for charges related to drug

trafficking in France. Gov’t Opp. at 15-16; PSR at ¶¶ 65-68. The following day, French

authorities deported him to the United States, where he was immediately arrested at Washington

Dulles International Airport in connection with this case. Gov’t Opp. at 2; PSR at 1.

On May 21, 2012, following a 23-day trial, a jury found Mr. Sitzmann guilty of

the single charge in the indictment, conspiracy to distribute and possess with intent to distribute

cocaine. United States v. Sitzmann, 893 F.3d 811, 818 (D.C. Cir. 2018); Jury Verdict Form at 1.

On October 23, 2015, the Court sentenced Mr. Sitzmann to 348 months (29 years) of

incarceration, to be followed by 120 months (10 years) of supervised release. Judgment at 2, 3.

The Court took into account twelve months of time Mr. Sitzmann served in French prison when

1 The Court has reviewed the following documents in connection with the pending motion: Indictment (“Indictment”) [Dkt. No. 001]; Jury Verdict Form (“Verdict Form”) [Dkt. No. 176]; Presentence Investigation Report (“PSR”) [Dkt. No. 273]; Judgment (“Judgment”) [Dkt. No. 290]; defendant’s June 1, 2020 Letter (“Letter 1”) [Dkt. No. 315]; defendant’s July 14, 2020 Letter (“Letter 2”) [Dkt. No. 317]; defendant’s September 17, 2020 Letter (“Letter 3”) [Dkt. No. 318]; Mr. Sitzmann’s pro se Request for Reduction of Sentence (“Def. Pro Se Mot.”) [Dkt. No. 319]; Defendant’s Motion for Compassionate Release Pursuant to 18 U.S.C. § 3582(c)(1)(A)(i) (“Def. Suppl. Mot.”) [Dkt. No. 327]; United States’ Opposition to Defendant’s Motion to Reduce Sentence Pursuant to the Compassionate Release Statute (“Gov’t Opp.”) [Dkt. No. 329]; and Defendant’s Reply to United States of America’s Opposition to Defendant’s Motion to Reduce Sentence Pursuant to the Compassionate Release Statute (“Def. Reply”) [Dkt. No. 333].

2 calculating this sentence, and Mr. Sitzmann was also given credit for approximately seven years

of time served in the D.C. jail. See Transcript of Day 3 of Sentencing [Dkt. No. 305] at 104.

Mr. Sitzmann appealed his sentence on four grounds, asserting improper venue, lack of

jurisdiction, Brady and Napue violations, and ineffective assistance of his trial counsel. See

United States v. Sitzmann, 893 F.3d at 819. The court of appeals affirmed Mr. Sitzmann’s

conviction on June 29, 2018. See id.

Mr. Siztmann, now seventy-one-years-old, is incarcerated at Federal Medical

Center (“FMC”) in Lexington, Kentucky. See Gov’t Opp. at 16. At the time Mr. Sitzmann filed

his motion for compassionate release, he had served approximately 12 years and 1 month of

his 29-year sentence. See Def. Ex. A. He has a projected release date of April 26, 2033. Def.

Exs. A-B. Mr. Sitzmann submitted three pro se letters concerning his request for a sentence

reduction, written on June 1, 2020, July 14, 2020, and September 17, 2020. See Letter 1;

Letter 2; Letter 3. 2 On October 10, 2020, the Court docketed Mr. Sitzmann’s pro se request for

sentence reduction. Def. Pro Se Mot. On April 9, 2021, Mr. Sitzmann filed through counsel a

supplemental motion for compassionate release, arguing that his failing health, advanced age,

and twelve years of time served are grounds for his early release. See Def. Suppl. Mot. at 6.

II. LEGAL STANDARD

“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.” Freeman v. United States, 564 U.S. 522, 526 (2011) (internal quotation marks and

citation omitted). One such exception is codified at 18 U.S.C. § 3582(c)(1)(A). As modified by

2 Mr. Sitzmann’s June 1, 2020 letter was inadvertently docketed twice. Compare Letter 1 [Dkt. No. 315], with Defendant’s Second June 1, 2020 Letter [Dkt. No. 316].

3 the First Step Act in 2018, Section 3582(c)(1)(A) allows courts to modify a sentence upon a

motion by a defendant “after the defendant has fully exhausted all administrative rights to appeal

a failure of the Bureau of Prisons to bring a motion on the defendant’s behalf or the lapse of 30

days from the receipt of such a request.” 18 U.S.C. § 3582(c)(1)(A).

Once a defendant satisfies this exhaustion requirement, they must show that

“extraordinary and compelling reasons warrant such a reduction.” 18 U.S.C. § 3582(c)(1)(A).

In evaluating extraordinary and compelling circumstances, courts historically have looked to a

policy statement promulgated by the U.S. Sentencing Commission. See U.S. SENT’G

GUIDELINES MANUAL (“U.S.S.G.”) § 1B1.13 cmt. n.1(A) (U.S. SENT’G COMM’N 2018); United

States v. Clark, Crim. No. 10-133, 2021 WL 5630795, at *2 (D.D.C. Dec. 1, 2021); United

States v. Speaks, Crim. No. 18-0111-1, 2021 WL 3128871, at *3 (D.D.C. July 23, 2021); United

States v. Hicks, Crim. No. 93-97-2, 2021 WL 1634692, at *3 (D.D.C. Apr. 27, 2021). The

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Related

Freeman v. United States
131 S. Ct. 2685 (Supreme Court, 2011)
United States v. Gregory Sitzmann
893 F.3d 811 (D.C. Circuit, 2018)
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980 F.3d 1178 (Seventh Circuit, 2020)
United States v. Thompson
984 F.3d 431 (Fifth Circuit, 2021)
United States v. Patricia Aruda
993 F.3d 797 (Ninth Circuit, 2021)

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