Compassionate release offers a critical mechanism for reducing federal prison sentences in extraordinary circumstances. Federal prison compassionate release cases are filed all the time, but they are still hard to win. This article is the first in our new recurring series detailing compassionate release wins from federal prison. 

The experienced federal criminal lawyers at Evergreen Attorneys are happy to share this information widely with the public. As federal compassionate release lawyers, Evergreen Attorneys make it a focus of our practice to stay up to date on the latest federal prison compassionate release cases.

Recent statutory changes and shifting judicial attitudes bring this important legal relief tool to the focus of both federal inmates and attorneys. Evergreen Attorneys pride ourselves on being the premier Colorado federal criminal defense law firm. We handle federal criminal cases from our office based near Denver all over the country. 

What are extraordinary and compelling reasons?

To get a sentence reduction (commonly called a compassionate release) an inmate must first demonstrate “extraordinary and compelling reasons” exist in his case. See 18 U.S.C. Section 3582(c)(1)(A). Our Denver federal criminal defense law firm covers the ins and outs of this legal definition in other blog posts. This one is just the higlights. Below is a list of the (updated 2023) qualifying “extraordinary and compelling” circumstances for compassionate release under U.S.S.G. 1B1.13 include:

• Medical Circumstances – Including serious medical conditions that substantially diminish the ability to care for oneself in prison or a terminal illness. (It is important to note that while the number of compassionate release federal prison motions increased significantly during the COVID-19 pandemic, the grant rates have stabilized at these modest levels. For instance, in 2020, the grant rate was nearly 17%, but this rate declined as the pandemic’s urgency diminished and vaccines became widely available. FY 2025 Q2 data shows that COVID-19/pandemic reasons only accounted for 0.6% of all granted releases.)

• Age & Time Served – The defendant is at least 65 years old, has served 10 years or 10% of their sentence, and is experiencing deteriorating health. 

• Family Circumstances – The death or incapacitation of the primary caregiver for a defendant’s minor child OR the incapacitation of a spouse or partner when the defendant is the only available caregiver.

• Victim of Abuse – If an inmate suffers sexual, physical, or other severe abuse while in custody or by corrections officials that cannot be mitigated by BOP.

• Unusually Long Sentence or Changes in Law – An “unusually long” sentence combined with a non‑retroactive change in law that would produce a lower sentence today, after at least 10 years served.

• Other Reasons – Any comparable, unforeseen hardship the court (post‑First Step Act) or the BOP identifies.

This blog series is dedicated to spotlighting the real cases where federal courts have granted compassionate release. Simply put, these are federal prison compassionate release wins. These cases demonstrate which arguments are most effective in securing compassionate release. Our federal criminal defense lawyers at Evergreen Attorneys stay up-to-date on these compassionate release grants to ensure our advocacy is informed, strategic, and aligned with what courts are actually granting today.

Compassionate Release Wins: Issued for Medical Reasons

United States v. Diggs

United States v. Diggs, No. 02-CR-1129, 2025 U.S. Dist. LEXIS 89743 (N.D. Ill. May 12, 2025)

• Facts: Curtis Diggs, a federal prisoner in his mid-50s, was serving a revocation sentence for a supervised release violation tied to a nonviolent drug trafficking offense. He developed serious eye conditions, including retinal detachment and cataracts, requiring four surgeries. Despite doctors’ orders for continued ophthalmologic care, the BOP failed to schedule follow-up care, risking permanent vision loss. Diggs claimed the lack of medical care amounted to extraordinary and compelling reasons under the Sentencing Commission’s guidelines for compassionate release.
• Issue: Whether Diggs’ severe untreated eye condition, coupled with the BOP’s failure to provide necessary medical care, constitutes “extraordinary and compelling reasons” justifying compassionate release? 
• Holding: Diggs’ federal prison compassionate release motion was granted, and the court reduced his sentence to time served.
• Rationale: The court found that Diggs’ serious eye condition met the Sentencing Commission’s definition of “extraordinary and compelling reasons” because the necessary specialized medical care was not being provided by the BOP, risking serious health deterioration. Weighing the § 3553(a) factors, the court noted that Diggs had served over 80% of his sentence, posed no imminent danger to the community, and had a viable release plan that could prevent future offenses. 

Compassionate Release Wins: Unusually Long Sentence or Changes in Law

United States v. Peace

United States v. Peace, No. 8:08-cr-00628-DCC-6, 2025 U.S. Dist. LEXIS 91831 (D.S.C. May 14, 2025)

• Facts: In 2009, Defendant Mr. Jonathan Peace was sentenced to a 262-month sentence for conspiracy to distribute crack cocaine. He sought compassionate release after serving over 15 years of this sentence, citing changes in sentencing law that would have resulted in a shorter sentence if applied today. At the time Peace was sentenced, the mandatory minimum for his offense was 20 years. Today, Peace would have faced a mandatory minimum sentence of 10 years and not have been deemed a career offender under the Sentencing Guidelines. 
• Issue: Whether the sentencing disparities in Peace’s case created “extraordinary and compelling reasons” for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A).
• Holding: The court granted Peace’s federal prison compassionate release motion and reduced his sentence to time served, followed by a period of supervised release.
• Rationale: If Mr. Peace were sentenced today, he would no longer be subject to either the career offender enhancement or the increased mandatory minimum based on his prior convictions. Due to this change in law, his applicable guideline range would be 151 to 188 months, which is significantly less than the 262 to 327-month range applicable. Mr. Peace was able to benefit from a Circuit Split on the issue of whether or not U.S.S.G. 1b1.13 is valid. In the Fourth Circuit, defendants can still use this provision of law. This issue is before the U.S. Supreme Court in the next term. 

United States v. Hormozi

United States v. Hormozi, No. 1:15-cr-000272-DAD, 2025 U.S. Dist. LEXIS 96230 (E.D. Cal. May 20, 2025)

• Facts: A 51-year-old California resident, Edmond Hormozi, was charged in 2015 with the following: one count of conspiracy to distribute a controlled substance, two counts of distribution of methamphetamine, and one count of attempt to distribute oxycodone. Subsequently, Mr. Hormozi was sentenced to 126 months of federal custody, followed by 36 months of supervised release. Mr. Hormozi later filed a motion for compassionate release, citing circumstances including: (1) he was needed by his family to help care for his 92-year-old mother who was in hospice care with a terminal diagnosis; (2) under U.S.S.G. Amendment 821, issued after his sentencing, he would not receive status points for having committed the offenses of conviction while under a criminal justice sentence which would have reduced his criminal history category from III to II (which may have caused the court to impose a lesser sentence than the 126-month sentence imposed); and (3) his rehabilitation efforts warranted a sentence reduction.
• Issue: Whether Hormozi qualifies for compassionate release under 18 U.S.C. § 3582(c)(1)(A) based on post-sentencing family circumstances, legal changes, and personal rehabilitation efforts.
• Holding: The court partially granted Hormozi’s motion for compassionate release from federal prison, granting a slight reduction in his original sentence. 
• Rationale: While the caretaking needs of the defendant’s mother did not warrant a reduction, Hormozi received a 6-month reduction on his 126-month sentence due to the court’s acknowledgment that the criminal history category III played a part in his sentencing. Had he been convicted with a category II, his sentence may have been lighter, therefore qualifying as an “extraordinary and compelling reason” for compassionate release under § 3553 (a). Also of note, the Court found that it was relevant that Hormozi served a significant amount of his sentence during the COVID-19 outbreak. The 

United States v. Davis

United States v. Davis, No. 1:05-CR-315-1, 2025 U.S. Dist. LEXIS 88688 (M.D.N.C. May 9, 2025)

• Facts: In 2006, 40-year-old William R. Davis was sentenced to a mandatory 32 years of imprisonment for his guilty plea for possession and brandishing a firearm during a drug trafficking crime. His projected release date was December 4, 2032. Davis filed for compassionate release, arguing that he received “stacked sentences” under 18 U.S.C. § 924(c), and if he were sentenced for the same crimes today his mandatory minimum sentence would be 18 years shorter. Davis also pointed to his mother’s advanced age as a reason for early release, stating that it was necessary that he assist in her care. 
• Issue: Whether Davis qualifies for compassionate release under 18 U.S.C. § 3582(c)(1)(A) based on post-sentencing changes in law and family circumstances.
• Holding: On May 9th, 2025, the court granted Davis’ federal prison compassionate release motion, concluding a reduction to time served (18 years).
• Rationale: To avoid unwarranted sentence disparities, See U.S.C. § 3553(a)(6), the court reduced Davis’ sentence. Under the law at the time the defendant was sentenced, his second 924(c) count was treated as a “second or subsequent” conviction under 18 U.S.C. § 924(c), thereby triggering a mandatory minimum sentence of 25 years. The First Step Act, enacted after the Defendant’s sentencing, requires that a “second or subsequent” conviction must “arise from a separate case” that is final. However, these changes were not made retroactively, id. at 174, the Fourth Circuit recognized that non-retroactive changes may be an extraordinary and compelling reason to support a modification of a sentence. Additionally, Davis showed great rehabilitative progress and the necessary means to provide care for his family. Of note, the Government did not oppose this particular 924(c) unstacking case. Prosecutors usually have opposed these. 

Compassionate Release Wins: Other Reasons

United States v. Collamore

United States v. Collamore, No. 2:10-cr-00158-NT, 2025 U.S. Dist. LEXIS 97500 (D. Me. May 22, 2025)

• Facts: Mr. Wayne Collamore, a 75-year-old Vietnam veteran with a long criminal history, was incarcerated at the low-security Federal Correctional Institution in Florida. Mr. Collamore was serving a 210-month sentence for escape from federal custody and possessing a firearm as a felon.Mr. Collamore filed for compassionate release, citing age, medical conditions, PTSD linked to combat service, and lack of adequate mental health treatment in prison. (In late 2020 and early 2021, Mr. Collamore filed his first two compassionate release requests based on concerns about COVID-19, which both were denied).
• Issue: Whether Collamore demonstrates “extraordinary and compelling reasons” justifying compassionate release under 18 U.S.C. § 3582(c)(1)(A), and whether a reduction aligns with the sentencing factors under § 3553 (a).
• Holding: The court granted Collamore’s motion for compassionate release from federal prison, reducing his sentence to time served pending a successful home inspection by the U.S. Probation Office Services.
• Rationale: Mr. Collamore received valid consideration for his compassionate release due to his untreated PTSD, advanced age, and deteriorating health. The Court recounted how the 75 year old Collamore had served a lengthy sentence previously and was now serving time for an escape charge from when he fled a halfway house. The Court found that the combination of Collamore’s facts were “similar in gravity” to the other enumerated extraordinary and compelling reasons under U.S.S.G. 1B1.13.  Additionally, Collamore’s sentence was deemed unusually long given the nonviolent nature of his crimes.

United States v. Taylor

United States v. Taylor, No. ELH-20-0392, 2025 U.S. Dist. LEXIS 100467 (D. Md. May 27, 2025)

• Facts: In November 2020, Ditrell Taylor was charged with possessing a firearm in furtherance of a drug trafficking crime, in violation of 18 U.S.C. § 924(c), a charge that carries a mandatory minimum sentence of 5 years and a maximum of life imprisonment. He was sentenced to 120 months in prison in 2022. In his motion for compassionate release, Taylor argued that the caregiver for his minor child or children had died or became incapacitated, leaving him as the only available caregiver. He also claimed additional extraordinary and compelling reasons for his release–his minor child’s caregiver died, leaving him as the sole caregiver while incarcerated. Taylor further contended that drug trafficking is not a crime of violence and that his criminal history category should have been category V rather than the imposed category VI.
• Issue: Whether Taylor qualifies for ‘extraordinary and compelling reasons’ for compassionate release due to family circumstances and unwarranted 924(C) impositions. 
• Holding: The court originally deemed Taylor ineligible for reduction because he couldn’t show extraordinary and compelling reasons. However, Taylor was granted a partial reduction of 12 months, taking his sentence from 120 months to 108 months. 
• Rationale: The Court held that Taylor was not required to show that there were no alternative caregivers for his minor child. This is an important holding, because the Government often wants to deny compassionate release motions based on family circumstances. Taylor’s grant was considered partially. While his immediate release was not granted, the court recognized his strides towards rehabilitation–including completed drug education, trauma, and anger management programs–and the unusually long nature of his sentence.

United States v. Sanchez-Rosado

United States v. Sanchez-Rosado, No. 6:17-cr-219-PGB-DCI, 2025 U.S. Dist. LEXIS 94510 (M.D. Fla. May 12, 2025)

• Facts: Jose Sanchez-Rosado was convicted of being a felon in possession of a firearm after working in a gun store and pawning a firearm despite his prior convictions, finding him in violation of 18 U.S.C. § 922(g)(1). His previous charges were battery, domestic violence, and robbery. The defendant’s calculated base offense level was 26, but because of his priors, he was deemed as an “armed career criminal” so his offense level rose to 33, producing an adjusted level of 30. His newest firearm charge held a mandatory minimum of 15 years in prison of which he served 8 years. Sanchez filed for compassionate release due to medical reasons, as he suffered from hypertension and anxiety disorder characterized by heart palpitations with chest pain and diaphoresis. Sanchez argued that these medical conditions could not be managed with the usual clinical interventions every 1-6 months by the BOP. Additionally, the defendant cited family circumstances as an extraordinary and/or compelling reason for early release. His 83-year-old father suffered from dementia, lived alone, and had no family to assist him with daily living.
• Issue: Whether Sanchez’s medical conditions and family circumstances qualify as “extraordinary and compelling reasons” justifying compassionate release under 18 U.S.C. § 3582(c)(1)(A).
• Holding: The court granted the defendant’s federal prison motion for compassionate release contingent on a supervised release plan from the BOP.
• Rationale: The court granted the defendant’s release motion after considering his adjusted offense level, unmanageable cardiac condition, family circumstances, and his efforts toward rehabilitation. The reality is that the Court appeared to realize how absurd the lengthy mandatory minimum 15 year sentence was in this case based on the facts at hand. Sometimes good facts made good case law. 

Turning Case Law into Action

Federal compassionate release lawyers are a different breed. This is not an area of law where someone can moonlight or dabble. The best compassionate release attorneys stay up to date every week on successful compassionate release cases.

As seen in these approved compassionate release motions, success depends on presenting clear, well-supported arguments that align with the court’s enforcement of justice. At Evergreen Attorneys, we stay informed on the latest rulings because we believe strategic advocacy makes a difference. Whether you’re seeking release for a loved one or building a motion from scratch, understanding what’s worked for others can be the key to opening that same door.

We’re here to help turn precedent into possibility. If you’re considering a compassionate release motion, contact our team to discuss your options at (303) 948-1489 or by email to [email protected].