United States v. Patterson

3 Citing cases

  1. United States v. Locke

    Case No. 10-CR-4 (E.D. Wis. Apr. 5, 2021)

    Even if it did, courts have generally required more than a mere diagnosis before granting compassionate release based on hypertension alone. See, e.g., United States v. Petersen, No. 3:16-cr-109 (SRU), 2020 U.S. Dist. LEXIS 227353, at *21 (D. Conn. Dec. 3, 2020); see also United States v. Patterson, No. 13-CR-193, 2020 U.S. Dist. LEXIS 205991, at *15-16 (E.D. Wis. Nov. 4, 2020). The record here contains no additional evidence that defendant's blood pressure increases his risk.

  2. United States v. Krueger

    Case No. 09-CR-103 (E.D. Wis. Feb. 12, 2021)   Cited 3 times

    Rather, the CDC guidance on the risks of COVID-19 must be viewed in light of the medical history and circumstances of the individual moving for compassionate release.United States v. Moore, No. 14-315-06, 2020 U.S. Dist. LEXIS 232051, at *6 (E.D. Pa. Dec. 10, 2020); United States v. Uriarte, No. 09-CR-332 (-03), 2020 U.S. Dist. LEXIS 215775, at *11 (N.D. Ill. Nov. 18, 2020) (noting that diagnosis with a CDC-recognized COVID-19 risk factor, such as obesity, does not automatically entitle a defendant to a sentence reduction, as each case must be assessed on its facts); United States v. Patterson, No. 13-CR-193, 2020 U.S. Dist. LEXIS 205991, at *16-17 (E.D. Wis. Nov. 4, 2020) ("While courts have properly relied on the expertise of the CDC in evaluating ยง 3582(c)(1)(A) motions during the COVID-19 pandemic, deeming an inmate diagnosed with any of the conditions listed by the CDC, regardless of severity, automatically eligible for compassionate release would be contrary to the individualized analysis contemplated by the statute."); see, e.g., United States v. Meyer, No. 14-CR-230, 2020 U.S. Dist. LEXIS 199117, at *20-21 (E.D. Wis. Oct. 27, 2020) (denying compassionate release where the defendant barely qualified as obese, and the medical records documented no problems related to his weight or hypertension). Despite the limitations in the evidence, the government acknowledges that defendant may be able to establish a medical reason for early release.

  3. United States v. Vazquez

    Case No. 2:06-CR-196-TC (D. Utah Dec. 9, 2020)   Cited 2 times

    The relationship between hypertension and COVID-19 is not fully understood, and district courts have disagreed about whether a hypertension diagnosis alone will support a request for compassionate release. See United States v. Patterson, No. 13-CR-193, 2020 WL 6485102, at *6 (E.D. Wis. Nov. 4, 2020) (finding that inmate's well-managed hypertension was by itself a sufficient basis for compassionate release); United States v. Richardson, No. 2:17-cr-00048, 2020 WL 3402410, at *3 (E.D. Cal. June 19, 2020) ("Here, Defendant's hypertension alone places him at significant risk of complications."); Segars v. United States, No. 16-cr-20222, 2020 WL 3172734, at *3 (E.D. Mich. June 15, 2020) (granting release where defendant's only CDC-identified preexisting condition was hypertension and explaining that "the diagnosis of hypertension at any level could plausibly lead to more severe COVID") (internal citations omitted); but see United States v. Jacobs, No. CR 5-64, 2020 WL 5704448, at *1 (W.D. Pa. Sept. 24, 2020) ("Courts have indicated that hypertension alone does not generally constitute an extraordinary and compelling circumstance that justifies relief under Section 3582."); United States v. Jones, No. 1:15-cr-00092, 2020 WL 5569824, at *4 (S.D. Ind. Sept. 17, 2020) ("The Court finds, c