. District courts are afforded significant discretion in applying their own local rules, United States v. Sanders, 992 F.3d 583, 586 (7th Cir. 2021), and Page identified no "exceptional circumstances" when he requested time to reply. Nor does he tell us on appeal how a reply brief would have made a difference-for instance, he does not contend that he would have provided evidence that he could not benefit from the vaccine.
The court did not acknowledge these assertions, but it assessed Crawford's individual circumstances, such as the facts underlying her convictions, and provided at least "one good reason" for its decision. United States v. Rucker, 27 F.4th 560, 563 (7th Cir. 2022); see United States v. Sanders, 992 F.3d 583, 588-89 (7th Cir. 2021).
Consistent with this proposition, other circuits to address the issue have held that an erroneous application of § 1B1.13 is harmless if "the court's weighing of the § 3553(a) factors independently supports its decision." United States v. Sanders , 992 F.3d 583, 588 n.3 (7th Cir. 2021) ; see, e.g. , United States v. Tomes , 990 F.3d 500, 503 (6th Cir. 2021) ("[E]ven if a district court wrongly constrains itself to § 1B1.13 to define extraordinary and compelling reasons for release, we can still affirm if the court uses § 3553(a) as an independent reason to deny relief."). We hold that although a district court addressing a compassionate release motion filed by a defendant may not construe U.S.S.G. § 1B1.13 as a binding constraint on its discretion, such an error is harmless if the court properly relied on the 18 U.S.C. § 3553(a) sentencing factors as an alternative basis for its holding.
This does not mean the court's opinion must address every issue that arises in compassionate-release proceedings. See United States v. Sanders , 992 F.3d 583, 588 (7th Cir. 2021). Instead, an opinion is adequate when it reflects individualized assessment of the prisoner's circumstances and primary arguments and makes the judge's thinking clear.
So we consider whether this compassionate release process was an abuse of the district court's "considerable discretion" under § 3582(c)(1)(A). United States v. Sanders , 992 F.3d 583, 587 (7th Cir. 2021). Newton's protests of the process have some purchase.
But we do not reweigh the factors ourselves, and instead ask only that the district court provide a reasonable explanation for its decision. See United States v. Sanders, 992 F.3d 583, 588 (7th Cir. 2021). The court here satisfied that requirement by highlighting a few good reasons, and no bad ones, for denying early release from prison.
In this case, however, Turner has not identified any information or arguments he might have presented in a reply that "would have changed" the outcome. United States v. Sanders, 992 F.3d 583, 586 (7th Cir. 2021). He has not shown that he was prejudiced by the absence of chance to reply.
Regardless of whether the District Court recognized that it was not constrained by the Sentencing Commission's policy statement, see United States v. Andrews, 12 F.4th 255, 259 (3d Cir. 2021), any error is harmless where Camara does not suffer from any condition that puts him at increased risk for COVID-19 and a vaccine is available to him. See id. at 260 (noting that "although the policy statement is no longer binding, it still sheds light on the meaning of extraordinary and compelling reasons"); United States v. Sanders, 992 F.3d 583, 588 n.3 (7th Cir. 2021) (determining that improper application of § 1B1.13 was harmless); see also Garrett v. Murphy, 17 F.4th 419, 433 (3d Cir. 2021) (stating "'widespread availability of the COVID-19 vaccine . . . eliminates' need for compassionate release" (quoting United States v. Burgard, 857 Fed.Appx. 254, 255 (7th Cir. 2021)).
"We will not upset a district court's denial of a motion for compassionate release unless the court abused its 'considerable discretion' under 18 U.S.C. § 3582(c)(1)(A)." United States v. Sanders, 992 F.3d 583, 587 (7th Cir. 2021). We find that the district court did not abuse its considerable discretion here.
Nevertheless, the legal error here was harmless. See United States v. Sanders, 992 F.3d 583, 588 n.3 (7th Cir. 2021) (determining that improper application of § 1B1.13 was harmless). For most prisoners, the availability of vaccines for COVID-19 "makes it impossible to conclude that the risk of COVID-19 is an 'extraordinary and compelling' reason for immediate release."