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defendantmotionleaselife imprisonment
defendantappealmotionwilllease

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United States v. Hartwell, Not Reported in Fed. Supp., 2022 WL 2161047

Facts

Erskine Larue Hartwell pled guilty to murder for hire in 2000 and was sentenced to life imprisonment. After his sentencing, he attempted to cooperate with authorities to reduce his sentence but provided false information regarding his involvement in other crimes. Hartwell later requested compassionate release due to health risks from COVID-19, but his claims were based on factors unrelated to medical issues, including his role in the crime and his prison conduct.

Hartwell submitted a request for compassionate release to the Warden at his facility of confinement, FCI Marianna. In that request, Hartwell sought compassionate release solely on the basis of health risks presented by COVID-19 (ECF No. 137-1).

Issue

Did Hartwell properly exhaust his administrative remedies before filing for compassionate release under 18 U.S.C. § 3582(c)(1)(A)?

Did Hartwell properly exhaust his administrative remedies before filing for compassionate release under 18 U.S.C. § 3582(c)(1)(A)?

Rule

Under 18 U.S.C. § 3582(c)(1)(A), a defendant must first request the Bureau of Prisons to file a motion for compassionate release on their behalf, and this requirement is mandatory.

After that, however, at least in our circuit, the defendant is entitled to file a motion with the Court either after he fully exhausts administrative rights to appeal or after the lapse of thirty days from the receipt of such a request by the Warden of the defendant's facility, whichever is earlier.

Analysis

The court analyzed whether Hartwell had exhausted his administrative remedies and found that he had not. Although he submitted a request to the Warden, the grounds for his motion in court differed from those presented to the Bureau of Prisons, which undermined the purpose of the exhaustion requirement. The court emphasized the importance of allowing the Bureau to evaluate the request before it reaches the court.

The court went on to hold: We have not yet occasion to consider whether in an order properly to exhaust, an inmate is required to present the same or similar ground for compassionate release in a request to the Bureau as in a motion to the court.

Conclusion

The court denied Hartwell's motion for compassionate release due to his failure to exhaust administrative remedies, allowing for the possibility of a future motion if properly supported.

According, the DEFENDANT'S MOTION FOR COMPASSIONATE RELEASE PURSUANT [sic] SECTION 603 (b) OF THE FIRST STEP ACT OF 2018 (ECF Nos. 125 (redacted) and 126-1 (sealed)) will be denied.

Who won?

The Government prevailed in this case because Hartwell did not meet the statutory requirements for filing a motion for compassionate release.

The Government raised as a threshold issue whether Hartwell exhausted his remedies as required by 18 U.S.C. § 3582(c)(1)(A).

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