The Supreme Court of the United States refused certiorari in Bryant v. United States. In May, the Eleventh Circuit became the first. So far only, the Court of Appeals in the country finds that district courts considering compassionate release requests must follow the exacting requirements outlined in USSG 1B1.13. Judges can only release offenders or decrease their sentences under Section 1B1.13 if they have terminal diseases, cannot care for themselves owing to medical issues, or have an impaired child or spouse. Every other Court of Appeals has ruled that district courts have the authority to decide whether an inmate’s reasons are compelling enough to justify a sentence reduction.
Because this is such a significant issue, and because courts seek consistency and uniformity across the country, the Supreme Court’s refusal to hear the case and rule whether the Eleventh Circuit was correct in Bryant came as a shock. As a result of the Supreme Court’s inactivity, an offender who applies a sentence reduction in Alabama, Florida, or Georgia will be subjected to a different and considerably more stringent standard than convicts with convictions in other states. Advocates expect that the Supreme Court will resolve the circuit divide soon, and additional plaintiffs have filed certiorari petitions, but it will not be in Bryant v. United States.