Here are some recent favorable (and useful) cases from the courts:
United States v. Frick, 2026 U.S. Dist. LEXIS 54160 (W.D. Wash. Mar. 16, 2026)
Compassionate Release Granted Where BOP Could Not Provide Necessary Medical Care
The district court granted compassionate release after finding that the Bureau of Prisons was unable to provide the specialized, ongoing medical care required for the defendant’s serious and deteriorating health conditions. The record included expert medical testimony establishing that the defendant faced a risk of serious deterioration or death without proper treatment, which the facility could not deliver. The court also relied on its prior firsthand findings—made during earlier proceedings—that BOP facilities lacked the ability to adequately treat these conditions. Despite the government’s opposition, the court concluded that these failures satisfied the “extraordinary and compelling” standard, and that release was appropriate given the defendant’s history on supervision and the ability to manage any risk through home confinement.
United States v. Batura, 2026 U.S. Dist. LEXIS 53805 (M.D. Fla. Mar. 16, 2026)
Compassionate Release Granted Based on Non-Retroactive Law Change Creating Massive Sentencing Disparity
The district court granted compassionate release after finding that an intervening change in the law created a massive disparity between the sentence originally imposed and what the defendant would receive today. At the time of sentencing, stacked sec. 924(c) counts resulted in a 385-month sentence, but under current law, he would face roughly 14 years. The court held this qualified as an “unusually long sentence” under the Sentencing Guidelines and met the requirement for “extraordinary and compelling reasons,” even though the change was not retroactive. The court also emphasized that the defendant had already served over a decade, demonstrated significant rehabilitation, and no longer posed a danger, rejecting the government’s argument that nonretroactive changes cannot support relief.
United States v. Aguayo-Montes, 2026 U.S. App. LEXIS 7750 (10th Cir. Mar. 17, 2026)
Conviction Vacated Where Counsel Failed to Warn Deportation Was Mandatory
The Tenth Circuit reversed and remanded after finding counsel provided constitutionally deficient advice by failing to clearly inform the defendant that his guilty plea would result in virtually automatic deportation. Instead of giving definitive guidance, counsel told him deportation was only a possibility and that he could deal with immigration consequences later, which the court found both misleading and inadequate under Padilla. Because the immigration consequences of the offense were clear and severe, counsel had a duty to provide equally clear advice—something he failed to do. The court held that this deficient performance warranted relief and required further proceedings on whether the defendant would have rejected the plea had he been properly advised.
United States v. Williams, 2026 U.S. App. LEXIS 7751 (10th Cir. Mar. 17, 2026)
Search Invalid Where Police Relied on Guilt by Association Instead of Real Threat
The Tenth Circuit vacated the conviction after finding the vehicle search violated the Fourth Amendment because officers lacked a valid basis to believe the passenger was dangerous. While officers suspected a weapon might be in the car, that alone was not enough—there must be specific facts showing an actual threat. Here, the driver had already been arrested, handcuffed, and removed from the scene, eliminating any immediate danger from him. The only justification for the search was the passenger’s relationship to the driver, with officers assuming she might try to access a weapon simply because she was his girlfriend. The court rejected this outright, holding that suspicion cannot be based on association alone.
The facts actually showed the opposite of danger. The passenger was calm, cooperative, had valid identification, and was not suspected of any crime. She followed all instructions, made no threatening movements, and gave officers no reason to believe she posed any risk. The court emphasized that once both occupants were secured and away from the vehicle, the justification for a protective sweep disappeared. Without real, individualized evidence of danger, the search was based on speculation—not reasonable suspicion—and therefore violated the Fourth Amendment.
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