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defendantmotionlease
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United States v. Vigneau, 473 F.Supp.3d 31

Facts

In 1998, Patrick M. Vigneau was convicted of engaging in a continuing criminal enterprise, possessing marijuana with intent to distribute, and money laundering, among other offenses. He was sentenced to 365 months of incarceration, which he has served for over twenty-three years. At the age of 55, he sought compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), arguing that his lengthy sentence was disproportionate to current standards for similar offenses and that he faced increased health risks due to COVID-19.

Mr. Vigneau has served over twenty-three years of the sentence. Now, at age 55, he seeks release under 18 U.S.C. § 3582(c)(1)(A)(i). Citing as extraordinary and compelling reasons justifying his release, Mr. Vigneau argues his CCE conviction is 'unusual and unique' in this District, his sentence length was overly long 'for conduct [marijuana use and distribution] that happens every day in the United States today,' and he is at an increased health risk because of an outbreak of COVID-19 where he is incarcerated.

Issue

Whether the Court can find extraordinary and compelling reasons under 18 U.S.C. § 3582(c)(1)(A)(i) to grant Patrick M. Vigneau's motion for compassionate release.

The Court answers each question in turn.

Rule

Under 18 U.S.C. § 3582(c)(1)(A), a court may reduce a sentence upon motion by the defendant if it finds that extraordinary and compelling reasons warrant such a reduction and that the reduction is consistent with applicable policy statements issued by the Sentencing Commission.

Under this statute, a court may reduce a sentence upon motion by the 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 by the warden of the defendant's facility whichever is earlier.'

Analysis

The Court determined that Vigneau's lengthy sentence was inconsistent with current sentencing practices for similar offenses, particularly given the changing legal landscape regarding marijuana. The Court also noted that Vigneau's age and the time served, along with the lack of danger he posed to the community, supported the finding of extraordinary and compelling reasons for his release.

Considering the FSA provision entitled 'Increasing the Use and Transparency of Compassionate Release,' the Court is hard pressed to find a clearer indication of Congress's intent to expand the court's implementation of compassionate release.

Conclusion

The Court granted Vigneau's motion for compassionate release, reducing his sentence to time served plus twenty-one days, followed by a period of supervised release.

The Court therefore: 1. GRANTS Patrick Vigneau's Motions for Compassionate Release (ECF Nos. 318, 321, and 323); 2. REDUCES Mr. Vigneau's sentence to time served plus twenty-one days from the date of this Order.

Who won?

Patrick M. Vigneau prevailed in the case because the Court found that extraordinary and compelling circumstances justified a reduction in his sentence, particularly in light of the changes in sentencing standards and the nature of his offenses.

The Court finds that the factors recounted above represent extraordinary and compelling circumstances supporting the need to reduce Mr. Vigneau's sentence.

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