United States v. King, No. 21-3196 (7th Cir. 2022)
Annotate this Case
King, who was sentenced to 216 months’ imprisonment following his guilty plea to three heroin charges, sought compassionate release, 18 U.S.C. 3582(c)(1)(A)(i), To establish the required “extraordinary and compelling reasons,” King cited intervening Seventh Circuit precedent (Ruth), which held that a conviction under an Illinois law does not count as a prior cocaine conviction for purposed of certain federal recidivist enhancements.
The Seventh Circuit affirmed the denial of relief. There is nothing “extraordinary” about new statutes or caselaw, or a claim that the sentencing judge erred in applying the Guidelines; these ordinary legal issues should be addressed by direct appeal or collateral review under 28 U.S.C. 2255. The Sentencing Commission’s policy statements contemplate the release of prisoners afflicted by severe medical conditions or risks, experiencing a family emergency, or otherwise in unusual personal circumstances. They do not hint that the sort of legal developments routinely addressed by direct or collateral review qualify a person for compassionate release. That the First Step Act lowered sentences for some cocaine crimes, enabled prisoners to seek compassionate release on their own motions, and more, did not modify the “extraordinary and compelling reasons” threshold for eligibility. King’s effort to use “Ruth” as a door opener under the compassionate-release statute is foreclosed by other decisions.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.