Appeal from the United States District Court
for the Northern District of Ohio at Cleveland.
No. 1:09-cr-00145-2—Patricia A. Gaughan, District Judge.
Decided and Filed: January 19, 2021
Before: KETHLEDGE, THAPAR, and READLER, Circuit Judges.
CHAD A. READLER, Circuit Judge. Federal prisoner Jeffrey Hampton seeks
compassionate release under 18 U.S.C. § 3582(c)(1)(A). He is not alone in that respect. Current
public health conditions have generated many similar requests, which the district courts have
worked expeditiously to resolve.
Over time, we too have lent a hand. Beginning largely with our decision in United States
v. Ruffin, 978 F.3d 1000 (6th Cir. 2020), we have issued a series of opinions articulating how
district courts, following enactment of the First Step Act, should analyze defendant-filed motions
seeking release under § 3582(c)(1)(A). In resolving those motions, district courts now face two
questions: (1) whether extraordinary and compelling circumstances merit a sentence reduction;
and (2) whether the applicable § 3553(a) factors warrant such a reduction. United States v.
Jones, 980 F.3d 1098, 1106 (6th Cir. 2020); see also Ruffin, 978 F.3d at 1006–07. A third
consideration, the § 1B1.13 policy statement, is no longer a requirement courts must address in
ruling on defendant-filed motions. U.S.S.G. § 1B1.13; United States v. Elias, --- F.3d ---, No.
20-3654, 2021 WL 50169, at *2 (6th Cir. Jan. 6, 2021) (citing Jones, 980 F.3d at 1108).
Here, the district judge, who was not the original sentencing judge, denied Hampton’s
motion in a two-sentence order. Order, United States v. Hampton, No. 1:09-cr-145 (N.D. Ohio
June 5, 2020). Citing “the reasons stated in the [government’s] brief,” the order concluded that
Hampton failed to meet the requirements of § 3582(c)(1)(A)(i). Id. At the time of that decision,
however, neither the district court nor the parties had the benefit of our current interpretation of
§ 3582(c)(1)(A). And in measuring that order against our current case-law backdrop, we do not
know whether the district court denied Hampton’s motion based upon permissible grounds
advanced by the government under § 3582(c)(1)(A)(i)—that Hampton failed to demonstrate
extraordinary and compelling circumstances—or instead denied Hampton release due to a strict
application of U.S.S.G. § 1B1.13, which the government invoked, but which is no longer a
mandatory step Hampton must satisfy. As a result, in this unique instance, the district court’s
assessment does not provide for “meaningful appellate review.” Jones, 980 F.3d at 1116; see
also United States v. Gaston, --- F. App’x ---, No. 20-3769, 2020 WL 6867187, at *2 (6th Cir.
Nov. 23, 2020). We therefore remand this case to the district court.