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United States v. Rodriguez

United States District Court for the Eastern District of Pennsylvania

April 1, 2020, Filed

Criminal Action No. 2:03-cr-00271-AB-1

Opinion

MEMORANDUM

We are in the midst of an unprecedented pandemic. COVID-19 has paralyzed the entire world. The disease has spread exponentially, shutting down schools, jobs, professional sports seasons, and life as we know it. It may kill 200,000 Americans and infect millions more.1 At this point, there is no approved cure, treatment, or vaccine to prevent it.2 People with preexisting medical conditions—like petitioner Jeremy Rodriguez—face a particularly high risk of dying or suffering severe health effects should they contract the disease.

Mr. Rodriguez is an inmate at the federal detention center in Elkton, Ohio. He is in year seventeen of a twenty-year, mandatory-minimum sentence for drug distribution and unlawful firearm possession, and is one year away from becoming eligible for home confinement. Mr. Rodriguez has diabetes, [*2]  high blood pressure, and liver abnormalities. He has shown significant rehabilitation in prison, earning his GED and bettering himself with numerous classes. He moves for a reduction of his prison sentence and immediate release under the "compassionate release" statute, 18 U.S.C. § 3582(c)(1)(A). He argues that "extraordinary and compelling reasons warrant such a reduction." 18 U.S.C. §3582(c)(1)(A)(i).

For Mr. Rodriguez, nothing could be more extraordinary and compelling than this pandemic. Early research shows that diabetes patients, like Mr. Rodriguez, have mortality rates that are more than twice as high as overall mortality rates.3 One recent report revealed: "Among 784 patients with diabetes, half were hospitalized, including 148 (18.8%) in intensive care. That compares with 2.2% of those with no underlying conditions needing ICU treatment."4

These statistics—which focus on the non-prison population—become even more concerning when considered in the prison context. Prisons are tinderboxes for infectious disease. The question whether the government can protect inmates from COVID-19 [*3]  is being answered every day, as outbreaks appear in new facilities. Two inmates have already tested positive for COVID-19 in the federal detention center in Elkton—the place of Rodriguez's incarceration.5 After examining the law, holding oral argument, and evaluating all the evidence that has been presented, I reach the inescapable conclusion that Mr. Rodriguez must be granted "compassionate release."

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2020 U.S. Dist. LEXIS 58718 *

UNITED STATES v. JEREMY RODRIGUEZ

Prior History: United States v. Rodriguez, 667 Fed. Appx. 355, 2016 U.S. App. LEXIS 12456 (3d Cir. Pa., July 6, 2016)

CORE TERMS

sentence, policy statement, compelling reason, inmates, prison, compassionate, motions, First Step Act, reduction, rehabilitation, conditions, factors, courts, disease, cases, circumstances, old policy, diabetes, infection, reasons, pandemic, impose sentence, seventeen years, compassionate-release, confinement, catchall, catchall provision, health condition, medical care, release date