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Compassionate release is one of the few mechanisms in the federal criminal justice system that allows incarcerated individuals to seek a reduction in their sentence because of extraordinary circumstances. These circumstances often involve serious medical conditions, advanced age, or unique family situations. The authority comes from 18 U.S.C. § 3582(c)(1)(A), which permits a court to reduce a term of imprisonment if extraordinary and compelling reasons justify the reduction and if it aligns with the sentencing factors in § 3553(a) (i.e. seriousness, deterrence, public protection, rehabilitation, and avoiding disparities, aiming for a sentence "sufficient, but not greater than necessary").
For many years, only the Bureau of Prisons (BOP) could file a motion for compassionate release on behalf of an inmate. This meant that very few such motions were filed, and even fewer were granted unless the inmate was near death. The First Step Act of 2018 changed that process by allowing prisoners themselves to petition courts directly once they have exhausted administrative remedies. This reform led to a sharp increase in compassionate release motions, especially during the COVID-19 pandemic, and prompted renewed debate about how to define what counts as “extraordinary and compelling.”
The U.S. Sentencing Commission, which issues the guidelines that inform sentencing and sentence reductions, took up the issue in 2023. After several years without a quorum, the Commission amended Guideline § 1B1.13 to provide more detailed and inclusive definitions of what may constitute extraordinary and compelling reasons. These amendments, which became effective in November 2023, were intended to make compassionate release more accessible and to clarify the standards courts should apply.
Among the important updates were provisions expanding the scope of qualifying medical conditions and family circumstances. The Commission recognized that inmates who need long-term or specialized medical care that cannot be adequately provided in prison may meet the threshold for compassionate release. The revised guideline also acknowledged other scenarios, such as caregiving responsibilities for incapacitated family members or situations involving abuse by correctional staff. In addition, the Commission allowed judges to consider unusually long sentences or disparities created by non-retroactive changes in law.
The key language relevant to medical cases states that extraordinary and compelling reasons exist when a defendant suffers from a medical condition requiring long-term or specialized care that is not being provided in custody, and without which the person faces a serious risk of health deterioration or death. This standard was central to the case of Troy Williams, whose appeal tested the meaning of adequate medical care in the context of compassionate release.
Troy H. Williams pleaded guilty in 2015 to drug trafficking, possession of a firearm as a felon, and money laundering. His sentencing range under the federal guidelines was between 262 and 327 months, but the court imposed a sentence of 198 months, followed by a decade of supervised release.
Williams suffers from two serious medical conditions: thrombophilia and recurrent deep vein thrombosis. Thrombophilia increases the tendency of the blood to clot, while deep vein thrombosis occurs when a clot forms in a deep vein, often in the legs. If not managed properly, these conditions can lead to pulmonary embolism or other life-threatening complications. Williams takes warfarin, a blood-thinning medication that requires regular testing to ensure that the dosage remains safe and effective.
When he entered the BOP, he was classified as a “Care Level 3” inmate, a category reserved for prisoners with complex medical needs requiring frequent clinical monitoring. Williams initially received adequate care at FCI Allenwood (Pennsylvania), but after being transferred to FCI Coleman in Florida, he claimed that his care had worsened. According to his motion, prison staff at Coleman were not testing his blood frequently enough, sometimes allowing as much as two months to pass between tests. He argued that this posed a significant health risk and amounted to inadequate medical care.
In 2024, Williams filed a motion for compassionate release, arguing that his medical treatment at FCI Coleman constituted extraordinary and compelling circumstances. He also emphasized his rehabilitation, the stability of his support system outside prison, and the lengthy period of supervised release that would follow any early release. The district court denied his motion, concluding that while Williams’s medical conditions were serious, the care he was receiving did not fall so far below accepted standards as to justify intervention. Williams then appealed to the Sixth Circuit Court of Appeals.
The Sixth Circuit affirmed the denial of compassionate release in a decision written by Judge Bloomekatz and joined by Chief Judge Sutton and Judge Boggs. The appellate court explained that under 18 U.S.C. § 3582(c)(1)(A), a defendant must show three things: that extraordinary and compelling reasons warrant a sentence reduction, that the reduction is consistent with the Sentencing Commission’s policy statements, and that the § 3553(a) sentencing factors support release.
The appellate panel focused on the first element—whether Williams’s medical situation and care met the threshold for extraordinary and compelling reasons. Williams relied on the argument that FCI Coleman’s medical team was not testing his blood often enough to manage his warfarin therapy safely. He cited a medical website recommending monthly blood testing for patients taking warfarin.
The court found this argument unpersuasive. It held that general medical guidance from a website did not establish what level of testing was medically necessary for Williams’s particular condition. The court emphasized that Williams’s medical records showed his blood levels remained within an acceptable range even during periods of less frequent testing and that his doctors had not needed to adjust his medication dosage during those times.
The record also contained a declaration from Dr. Kendes Archer, the Clinical Director at FCI Coleman, who stated that Williams’s condition was stable and could be fully managed at the facility. Dr. Archer’s statement was the only expert medical evidence before the court. The appellate panel deferred to this expert opinion, finding that the district court had not erred in concluding that Williams was receiving adequate care.
Williams also claimed that repeated lockdowns at FCI Coleman had interfered with his medical treatment, a common reason for missed treatments and appointments. He cited one instance when a scheduled blood test was missed because of a lockdown and referenced a report by an outside organization describing frequent lockdowns at the facility. The court noted that the report was more than two years old and that there was only one documented instance in Williams’s medical records where a lockdown affected his care.
In the end, the Sixth Circuit held that Williams had not demonstrated extraordinary and compelling reasons for release. I reached out to attorney Phillip DiLucente about his thoughts on compassionate release and specifically, this case. DiLucente said,
“President Trump’s First Step Act restored a measure of humanity to the federal prison system. Compassionate release is not about excusing crime. It is about recognizing when continued incarceration no longer serves justice. The law has empowered courts to weigh a person’s medical needs, family responsibilities, rehabilitation, and dignity. In many ways, the First Step Act rebalanced federal sentencing to reflect both accountability and mercy. This decision does not seem to support that."
The Williams decision illustrates how challenging it remains for incarcerated individuals to obtain compassionate release based on medical conditions. Even though the Sentencing Commission’s amendments were intended to make relief more accessible, courts continue to require strong, detailed evidence showing both serious illness and inadequate care. Inmates must demonstrate not just that they have a severe condition, but that the BOP cannot or will not provide the treatment necessary to manage it safely.
The court’s reasoning also reflects a broader judicial reluctance to second-guess prison medical staff. Judges typically defer to the opinions of prison doctors unless there is clear and credible evidence to the contrary. For appellate courts, that deference is even greater; they will rarely disturb a district court’s factual findings unless those findings are plainly wrong. This standard makes it difficult to overturn denials of compassionate release once they have been issued at the trial court level.
At the same time, the decision leaves room for successful petitions in cases where inmates can document a genuine failure of medical care. The Sentencing Commission’s updated policy statements emphasize that when necessary care is unavailable, or when an inmate faces a substantial risk of health deterioration or death, those circumstances may justify early release. Williams’s case demonstrates what courts consider insufficient: a stable condition, ongoing treatment, and no clear evidence of harm or risk resulting from the prison’s care.
DiLucente told me, "By permitting the early release of seriously ill individuals who no longer pose a danger to the public, the Act has reduced the financial burden on taxpayers who would otherwise shoulder the cost of extensive medical treatment and end-of-life care in prison. Looking ahead, I believe compassionate release should be expanded and this decision does the opposite. Far too many people remain in federal custody for non-violent offenses, and continued incarceration in those cases serves little purpose beyond human and economic cost.”
Although the Sixth Circuit’s decision reaffirmed the denial of relief for Troy Williams, it also highlighted the seriousness with which courts treat these motions. Compassionate release remains a vital tool for addressing cases where incarceration no longer serves justice or endangers an inmate’s health. But as Williams’s case shows, the burden of proof remains steep, and success often depends on the strength of the record and the clarity of the evidence presented.
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