- US v. Tony Collins, 1:10-cr-00336-CCB (Mar. 30, 2020) (Memorandum), Dkt. 1038
Court granted defendant's motion for reduction in sentence pursuant to 404 of the First Step Act to time served. Defendant was originally sentenced on February 2, 2012 as a career offender to 160-months in prison following a Rule 11(c)(1)(C) plea on October 18, 2011, for a conspiracy to (which ended in June 2010) to distribute and possess with intent to distribute both 50 grams or more of crack cocaine and 5 kilograms or more of powder cocaine within 1000 feet of a public housing facility. Defendant "is a non-violent drug offender who would be eligible for release from BOP custody in December 2020," but requested a reduction to time served so that he can be released to a VOA. After determining that the defendant was eligible for a sentence reduction and considering 3553 factors, the Court noted that it "must acknowledge the extraordinary circumstances present in the community as a result of the COVID-19 pandemic," notwithstanding the fact that the defendant had not proffered "an underlying health condition which makes him more susceptible to the effects of the virus." In footnote 2, the Court rejects the government's argument that the defendant's motion was an "'end run' around the court's general lack of jurisdiction over release from VOA. To the contrary, a lack of jurisdiction over sentenced prisoners generally in no way supports a failure to exercise jurisdiction that has been given to the Court by Congress under the First Step Act."- US v. Tony Collins, 1:10-cr-00336-CCB (Mar. 30, 2020) (Order), Dkt. 1039
- Defendant's Motion for Imposition of a Reduced Sentence Pursuant to Section 404 of the First Step Act, US v. Tony Collins, 1:10-cr-00336-CCB (Mar. 27, 2020), Dkt. 1036
- Government's Response In Opposition to Petitioner's Motion for Imposition of a Reduced Sentence Pursuant to Section 404 of the First Step Act, US v. Tony Collins, 1:10-cr-00336-CCB (Mar. 29, 2020), Dkt. 1037
- State of Georgia v. Denton, No. 04R-330 (Sup. Ct. Ware Cty. Apr 8, 2020) (Consent Order Releasing on Bond)
- State of Georgia v. Denton, No. 04R-330 (Sup. Ct. Ware Cty. Apr 6, 2020) (Emergency Motion for Immediate Release)
Denton was sentenced to life imprisonment 14 years ago but was granted a new trial as her conviction was based on unreliable "bitemark" evidence at trial. Attached is a letter from defense counsel noting the State's delay in responding and copying major media outlets.
- State of Georgia v. Denton, No. 04R-330 (Sup. Ct. Ware Cty. Apr 6, 2020) (Emergency Motion for Immediate Release)
- Jeff v. Rose, No. 17-15009 (9th Cir. Apr. 9, 2020)
(Order Granting Motion for Release, Emergency Motion for Release, Opposition, Reply). Dkt. 59-61
Ninth Circuit grants habeas petitioner's emergency motion for release finding that the State's opposition to Rose's motion does not meaningfully contest that the Rule 23(c) factors governing weigh in favor of release. -
US v. Hector, No. 20-4183 (4th Cir. Mar. 27, 2020)
Order of Remand to Reconsider Denial of Stay Imprisonment Pending Appeal, Dkt. 17
Fourth Circuit orders remand of district court's denial of release pending appeal "for the limited purpose of having the district court consider in the first instance the severity of the risk that the COVID-19 virus poses to appellant given her existing medical conditions"-
US v. Hector, No. 2:18-cr-0003-JPJ-PMS (WDVA Mar 27, 2020)
Order Reversing Prior Denial of Stay Imprisonment Pending Appeal, Dkt. 748
granting release pending sentencing after Fourth Circuit remanded detention decision requiring court to specifically consider extraordinary danger posed by COVID-19 to folks in prison
-
US v. Hector, No. 2:18-cr-0003-JPJ-PMS (WDVA Mar 27, 2020)
-
US v. Kennedy, No. 5:18-cr-20315-JEL-EAS (ED MI Mar 27, 2020)
Order Temporarily Revoking Detention, Dkt. 77 Release warranted under 18 U.S.C. SS 3142(i)(4), both due to (1) risk of COVID-19 and (2) difficulty preparing defense while detained due to limits facility placed in response to COVID-19. Good language about how if courts wait for a case in any specific facility it will be too late: "waiting for either Defendant to have a confirmed case of COVID-19, or for there to be a major outbreak in Defendant's facility, would render meaningless this request for release. Such a failure to act could have devastating consequences for Defendant and would create serious medical and security challenges to the existing prison population and the wider community." Id. at 13. -
US v. Michaels, No. 8:160-cr-76-JVS (C.D. Cal. Mar. 26, 2020)
Minute Order, Dkt. 1061 " Michaels has demonstrated that the Covid-19 virus and its effects in California constitute 'another compelling reason'" justifying temporary release under SS 3142 -
US v. Garlock, No. 1:18-cr-00418-VC, 2020 WL 1439980 (ND Cal Mar 25, 2020)
Order Deferring Surrender Date, Dkt. ss
Sua sponte decision extending defendant's surrender date from June 12, 2020 to September 1, 2020. No apparent health risks. "By now it almost goes without saying that we should not be adding to the prison population during the COVID-19 pandemic if it can be avoided. Several recent court rulings have explained the health risks--to inmates, guards, and the community at large--created by large prison populations. (See, e.g., United States v. Stephens, No. 15-cr-95-AJN, 2020 WL 1295155, at *2 (S.D.N.Y. Mar. 19, 2020); United States v. Barkman, No. 3:19-cr-0052-RCJ-WGC, 2020 U.S. Dist. LEXIS 45628 (D. Nev. Mar. 17, 2020); In the Matter of Extradition of Toledo Manrique, No. 3:19-mj-71055-MAG-1 (TSH), 2020 WL 1307109 (N.D. Cal. Mar. 19, 2020). The chaos has already begun inside federal prisons--inmates and prison employees are starting to test positive for the virus, quarantines are being instituted, visits from outsiders have been suspended, and inmate movement is being restricted even more than usual. See, e.g., Sadie Gurman, Bureau of Prisons Imposes 14-Day Quarantine to Contain Coronavirus, Wall Street Journal (March 24, 2020)
- US v. Underwood, No. 8:18-cr-201-TDC (D.Md Mar 31, 2020) Order Denying Release Request Under "All Writs Act", Dkt. 179
-
US v. Nkanga, No. 1:18-cr-713-JMF (SDNY Mar 31, 2020)
Order Denying Granting Sentence Reduction On motion for immediate release under 18 U.S.C. 3145(c), also new trial or correction of error in sentence. Court states "Moreover, there are many cases where temporary release of an inmate would be the rational and just course of action, but the law does not give a judge the authority to take it. This is one such case, and it underscores the need for a swift congressional and executive response." FN 4 on page 10 states that the court: "does not address other arguments for relief, such compassionate relief under 18 U.S.C. SS 3582(c) or temporary release by the BOP pursuant to 18 U.S.C. SS 3622" -
US v. Ruan, No. 1:17-cr-12653-D (11th Cir. Apr 2, 2020)
Time Sensitive / Emergency Motion for Appeal Bond -
US v. Grobman, No. 1:18-cr-20989-RKA (SD FL Mar 29, 2020)
Order Granting Release Motion Pending Sentence releasing defendant convicted after trial of fraud scheme in light of "extraordinary situation of a medically-compromised detainee being housed at a detention center where it is difficult, if not impossible, for [the defendant] and others to practice the social distancing measures which government, public health and medical officials all advocate" -
US v. French, No. 1:21-cr-00160-JAW (1st Cir. Mar 26, 2020) Order Denying Emergency Bail Without Prejudice to File in District Court, Dkt. 855
Denying emergency motion for release but noting a "substantial question" is raised that requires a fact-dependent inquiry to be conducted by the district court -
US v McLean, No. 1:19-cr-00380-RDM (D.D.C. Mar 28, 2020), Order Setting Conditions of Release
Order granting emergency motion for release after earlier detention order in 18 U.S.C. SS 922(g), 21 U.S.C. SS 841(b)(1)(C), and 18 U.S.C. SS 924(c) case based on COVID-19 threat where defendant is 55 years old and suffers from diabetes. - US v. Robinson, No. 1:16-cr-0098-CKK (D.D.C. Mar 27, 2020), Defendant's Reply to Government's Response to Motion for Release Pending New Trial, Dkt. 373
-
US v. Hutchings, No. 1:19-cr-00361-BAH (D.D.C. Mar 26, 2020), Order Setting Conditions of Release, Dkt. 41-1
setting conditions of release after earlier detention order in conspiracy to defraud United States case based on COVID-19 threat
-
US v. Courtney, No. 1:19-cr-00413-TJK (D.D.C. Mar 20, 2020), Order Setting Conditions of Release, Dkt. 27
setting conditions of release on consent after earlier detention order in 18 U.S.C. SS 922(g) case based on COVID-19 threat and defendant's "unique medical concerns
-
Application for Bail Pending Appeal (3/21/20) (D. Guam)
By Brianna Mircheff, Assistant Federal Defender, Federal Defender Southern District of California
-
Sample - Attorney Declaration in Support of Bail Pending Appeal (redacted)(3/19/20)
By Davina Chen, Sentencing Resource Counsel
-
Sample - Renewed Application for Bail Pending Appeal (redacted) (3/19/20)
By Davina Chen, Sentencing Resource Counsel
- Defendant's Emergency Appeal of Magistrate Judge's Detention Order (3/18/20) (D. Ariz.)
- Motion for Extension of Time to File NOA (3/16/20) (D.P.R.)