What is the standard of review in the context of a compassionate release application?

MultiRegion, United States of America

The following excerpt is from United States v. Alimi, 20-30204 (9th Cir. 2021):

Alimi contends that the district court erred by applying U.S.S.G. 1B1.13 as an applicable policy statement, erred in its 18 U.S.C. 3553(a) and dangerousness analysis, and wrongly concluded that Alimi's obesity alone could not constitute an extraordinary and compelling reason for release. We need not decide whether the district court erred in its "extraordinary and compelling" analysis because the court did not abuse its discretion in independently concluding that the 3553(a) sentencing factors did not support relief. See United States v. Keller, 2 F.4th 1278, 1281, 1284 (9th Cir. 2021) (stating standard of review and explaining that court may deny compassionate release based on its 3553(a) analysis alone). As the district court observed, Alimi's criminal history, the seriousness of his offense, and the need to protect the public weighed against shortening his sentence by more than half. See 18 U.S.C. 3553(a)(1), (a)(2)(A), (C). Moreover, contrary to Alimi's argument, the court did not rely on any clearly erroneous facts in calculating the remaining time on Alimi's custodial sentence.

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