Adequate Prison Care and § 3553(a) Balancing Can Defeat Compassionate Release Even for End-Stage Organ Disease

Commentary on United States v. Korey Moody, No. 24-4095 (6th Cir. Oct. 29, 2025) (Not Recommended for Publication)

Introduction

This Sixth Circuit decision addresses a recurring and difficult question in federal sentencing: when a defendant demonstrates “extraordinary and compelling reasons” for compassionate release under 18 U.S.C. § 3582(c)(1)(A)—here, end-stage kidney disease—can the district court nevertheless deny relief based on the statutory sentencing factors in 18 U.S.C. § 3553(a)? In an unpublished opinion authored by Judge Julia Smith Gibbons, the court affirms the district court’s denial of compassionate release to Korey Moody, emphasizing the breadth of district-court discretion and the centrality of § 3553(a) balancing even in the face of severe, qualifying medical conditions.

The case arose after Moody, a leader in a multi-drug trafficking conspiracy involving cocaine, crack, heroin, fentanyl, fentanyl analogues, and methamphetamine, was sentenced in 2022 to 144 months’ imprisonment (mid-Guidelines within a 130–162 month range). Diagnosed with kidney disease in 2010 and on thrice-weekly dialysis, Moody sought compassionate release in 2024 when his disease progressed to end-stage renal failure. He argued that dialysis had become increasingly difficult due to vascular complications and that transplantation—unavailable to him during incarceration—was his best chance for survival. The district court acknowledged that Moody’s condition constitutes an “extraordinary and compelling” reason but denied relief under § 3553(a). The Sixth Circuit affirms, concluding there was no abuse of discretion.

Summary of the Opinion

The Sixth Circuit holds that:

• Moody’s end-stage kidney disease qualifies as an “extraordinary and compelling” reason under U.S.S.G. § 1B1.13(b)(1)(A) and prior Sixth Circuit authority recognizing end-stage renal failure as qualifying.
• Nonetheless, the district court did not abuse its discretion in finding that the § 3553(a) factors outweighed those medical considerations. The court stressed:
  • The seriousness of Moody’s offenses and his leadership role in a significant, multi-drug conspiracy involving fentanyl and analogues.
  • His extensive criminal history and the risk of reoffending.
  • His limited time served—less than a quarter of a 12-year sentence—undermining the goals of punishment, deterrence, and rehabilitation.
  • Evidence that he is receiving adequate medical care in prison through routine dialysis and necessary surgeries, despite transplant ineligibility during incarceration.
• The district court’s analysis sufficiently considered Moody’s pretrial and post-sentencing conduct, his health, and the record; it was not required to address every argument explicitly.
• Because the appellate court cannot reweigh § 3553(a) considerations and found no legal or factual error, the denial is affirmed.

Analysis

Precedents Cited and Their Influence

• United States v. Jones (6th Cir. 2020): Provides multiple guideposts. First, it states that denials of compassionate release are reviewed for abuse of discretion and that district courts must articulate “specific factual reasons,” including due consideration of § 3553(a). The panel leverages Jones to confirm the standard of review and to validate the district court’s thorough explanation.
• United States v. Elias (6th Cir. 2021) and United States v. Flowers (6th Cir. 2020): Reinforce the contours of abuse-of-discretion review—reversal is warranted for clearly erroneous factual findings, use of an erroneous legal standard, or improper application of law. The court uses Elias to emphasize appellate correction of error without abandoning deference.
• United States v. Ruffin (6th Cir. 2020): Clarifies that denials can be set aside for substantively unreasonable balancing of § 3553(a), but also underscores the district court’s “substantial” discretion. The panel cites Ruffin to mark the high bar for reversal.
• United States v. Tomes (6th Cir. 2021): Articulates the now-familiar three-step compassionate release framework: (1) extraordinary and compelling reasons; (2) applicable policy statements; (3) § 3553(a) balancing. The panel applies this structure and affirms on step three.
• United States v. Owens (6th Cir. 2021): Confirms that an appellate court can affirm on any one of the three steps; the district court need not decide steps found unnecessary once one is dispositive. The panel invokes this to justify affirmance on § 3553(a) grounds alone.
• U.S.S.G. § 1B1.13(b)(1)(A): The Sentencing Commission’s policy statement enumerates “end-stage organ disease” as an extraordinary and compelling medical reason. The panel highlights that Moody’s condition satisfies this category, aligning with post-amendment guidance.
• United States v. Jones (No. 21-1232, 6th Cir. 2021): An unpublished decision specifically recognizing end-stage kidney failure as extraordinary and compelling; used to bolster that element in Moody’s favor.
• United States v. Richardson (6th Cir. 2020): Demonstrates that a district court’s express statement that it reviewed the motion, record, and § 3553(a) factors suffices to show it considered post-sentencing conduct even if not exhaustively discussed. The panel relies on Richardson to reject Moody’s argument that the district court ignored his conduct on pretrial release and in prison.
• United States v. Rafidi (6th Cir. 2021) and United States v. Lapsins (6th Cir. 2009): Establish that a district court need not explicitly address each argument the defendant raises. Cited to rebut Moody’s contention that the court erred by not addressing every point.
• United States v. Kimball (6th Cir. 2021), United States v. Wright (6th Cir. 2021), United States v. Wilson (No. 24-1313, 6th Cir. Mar. 5, 2025), and United States v. Sain (No. 24-1246, 6th Cir. Dec. 9, 2024): Illustrate consistent affirmances of denials grounded in § 3553(a), reinforcing the circuit’s pattern of deferring to reasoned district-court balancing.
• United States v. Hampton (6th Cir. 2021): A rare reversal for inadequate reasoning—a two-line order referencing the government’s brief. The panel contrasts Hampton with the reasoned, record-based analysis here.
• United States v. Harvey (6th Cir. 2021): Notes that even form orders may suffice; used to show the comparatively robust reasoning in this case clears the minimal threshold.
• United States v. Perez-Rodriguez (6th Cir. 2020) and United States v. Ely (6th Cir. 2006): Reiterate that district courts are best positioned to weigh § 3553(a) factors and that appellate courts cannot reweigh them simply because the defendant urges a different balance.

Legal Reasoning and Path to Decision

The panel’s analysis unfolds within the standard three-step framework for compassionate release under § 3582(c)(1)(A):

• Step 1: Extraordinary and compelling reasons. The court agrees that end-stage kidney disease qualifies. This conclusion rests on the Commission’s policy statement, which expressly lists “end-stage organ disease,” and the Sixth Circuit’s prior recognition that end-stage renal failure fits that category.
• Step 2: Policy statements. The opinion treats U.S.S.G. § 1B1.13 as applicable and satisfied on the medical-reasons prong; however, the ultimate decision does not turn on any unresolved policy-statement debate, because the court affirms on step three.
• Step 3: § 3553(a) factors. The district court weighed:
  • Nature and circumstances of the offense: Moody led a sizable drug conspiracy, including fentanyl and analogues—offenses with grave public-safety implications.
  • History and characteristics: A substantial record of drug-related convictions, obstruction-type conduct, and a firearm disability offense, extending back to age eighteen. Notably, the court emphasized that the kidney disease did not deter Moody’s criminal conduct in the past.
  • Need for the sentence: With less than one-quarter of the sentence served, early release would undercut seriousness, deterrence, protection of the public, and rehabilitation.
  • Medical care while incarcerated: Under § 3553(a)(2)(D), the court found that Moody is receiving routine dialysis and necessary surgeries in prison. While transplant is unavailable during incarceration and would be medically preferable, the existing regimen was considered adequate.

On appeal, Moody raised three main challenges:

• Failure to consider pretrial and post-sentencing conduct. The panel, citing Richardson, found “ample proof” the district court considered these factors because it explicitly stated that it reviewed the record, the motion (which highlighted favorable conduct), and the § 3553(a) factors. No abuse of discretion.
• Failure to consider health within the § 3553(a) analysis. The district court did so, expressly addressing § 3553(a)(2)(D) by finding Moody is receiving routine dialysis and surgical access procedures, notwithstanding ineligibility for a transplant during incarceration.
• Clearly erroneous finding of adequate medical care. The panel rejected this challenge. Even Moody’s own medical submission (Dr. Keller’s opinion) acknowledged that he was receiving dialysis and surgeries to maintain access, although transplant would be the best treatment. The district court’s finding that care was adequate—if not optimal—was not clearly erroneous.

Finally, the panel reiterates that (1) district courts need not address every argument in writing (Rafidi and Lapsins), (2) reversal is reserved for exceptional reasoning inadequacies (Hampton), and (3) the appellate court cannot reweigh § 3553(a) factors (Ely). In short, the district court’s reasoned and record-grounded decision fell well within its discretion.

Impact and Forward-Looking Implications

Although unpublished, this decision reinforces several practical and doctrinal points in the Sixth Circuit’s compassionate-release jurisprudence:

• Extraordinary-and-compelling is necessary but not sufficient. Even severe, enumerated medical conditions—like end-stage organ disease—do not create a presumption of release. § 3553(a) remains potentially dispositive.
• Adequate versus optimal care. The court’s acceptance that dialysis and surgical maintenance constitute “adequate” care, despite the unavailability of transplantation during incarceration, signals that defendants need more than a medical showing of a better, non-carceral option. They must prove that BOP care is insufficient to meet their medical needs or that § 3553(a) otherwise favors release in spite of adequate care.
• Public safety and offense seriousness retain primacy. Significant drug-trafficking conduct—especially leadership roles and fentanyl-related conduct—will weigh heavily against release, particularly where little of the sentence has yet been served and the record reflects recidivist behavior.
• Process suffices when reasons are articulated. District courts that tie their analysis to the record and § 3553(a), referencing the parties’ briefing and the defendant’s conduct, can expect affirmance. They need not exhaustively catalog every argument.
• What changes the outcome? Successful motions will likely require:
  • Compelling evidence that BOP cannot provide necessary care (not just that better care exists outside), such as repeated treatment failures, inability to maintain dialysis access, or documented lapses in medically necessary interventions.
  • Substantial proof of sustained rehabilitation and low risk to the community, including documented programming, discipline-free records, strong release plans, and medical constraints that materially reduce recidivism risk.
  • Sentencing equity considerations (e.g., unusually long sentences relative to co-defendants with similar records) and a greater portion of the sentence already served.

Complex Concepts Simplified

• Compassionate release (§ 3582(c)(1)(A)): A mechanism allowing courts to reduce a sentence for “extraordinary and compelling reasons,” after considering Sentencing Commission guidance and § 3553(a) factors. A defendant may file after exhausting administrative remedies.
• Extraordinary and compelling reasons: Serious reasons justifying reconsideration of a sentence. The guideline § 1B1.13(b)(1)(A) lists “end-stage organ disease.” Qualifying reasons open the door but do not guarantee release.
• § 3553(a) factors: The statutory goals of sentencing—punishment, deterrence, public protection, rehabilitation—and the nature of the offense and offender, among others. Even with extraordinary circumstances, these factors can outweigh release.
• Abuse of discretion: A deferential appellate standard. The appellate court will not reverse unless the district court used the wrong legal rule, made clearly erroneous factual findings, or balanced the factors in an unreasonable way. Appellate courts cannot reweigh the factors simply because they would decide differently.
• Adequate vs. best medical care: § 3553(a)(2)(D) asks whether the sentence provides needed medical care “in the most effective manner.” Courts generally look for adequacy—whether the defendant is receiving medically necessary care—rather than requiring the best possible care available in the community.
• Not required to address every argument: A district court’s explanation must be reasoned and tied to the record, but it need not rebut each discrete point raised by the defendant to avoid abuse of discretion.

Case Background and Procedural Posture

• Offenses: Moody pled guilty in 2020 to possession with intent to distribute cocaine. In 2021, he pled guilty in a separate case to conspiracy to distribute cocaine, crack, heroin, fentanyl, fentanyl analogue, and methamphetamine.
• Sentencing (Feb. 25, 2022): Guidelines range 130–162 months (offense level 28, CHC V). The court imposed 144 months and 3 years’ supervised release. At sentencing, the defense flagged Moody’s kidney failure and transplant issues; the government sought a high-end sentence due to his leadership role and criminal history. Moody’s sentencing removed him from the Cleveland Clinic transplant list.
• Compassionate release motion (Sept. 20, 2024): Based on end-stage kidney failure and complications with dialysis access, supported by Dr. Jeffrey Keller’s opinion that dialysis had become more difficult due to a brachial artery aneurysm and that transplant would be curative.
• District court denial (Dec. 10, 2024): Found extraordinary and compelling reasons but denied on § 3553(a) grounds, citing offense seriousness, danger to the community, limited time served, and adequacy of current medical care.
• Appeal: The Sixth Circuit affirmed, finding no abuse of discretion.

Key Takeaways

• End-stage organ disease qualifies as an extraordinary and compelling reason, but that threshold finding does not control the outcome.
• District courts have “substantial” discretion to deny compassionate release based on § 3553(a), especially where offenses were serious, criminal histories lengthy, and only a small portion of a sentence has been served.
• Evidence that the BOP is providing adequate medical care—though not the optimal community standard—can be sufficient to deny release under § 3553(a)(2)(D).
• Reasoned, record-tethered orders that expressly consider § 3553(a) will be affirmed; courts are not required to address every argument in writing.
• Appellate courts will not reweigh the § 3553(a) factors; successful appeals must demonstrate legal error, clearly erroneous factual findings, or substantively unreasonable balancing.

Conclusion

United States v. Korey Moody reinforces a central throughline of the Sixth Circuit’s compassionate-release jurisprudence: establishing that a defendant suffers from a recognized “extraordinary and compelling” medical condition is only the first step. The ultimate question remains whether release aligns with the § 3553(a) sentencing goals. Here, the district court reasonably determined that Moody’s leadership in a serious, fentanyl-related drug conspiracy, his recidivist history, the small fraction of sentence served, and the adequacy of prison medical care collectively outweighed his substantial medical hardship. On deferential review, the Sixth Circuit affirmed.

For practitioners, Moody underscores the evidentiary and advocacy burdens in this arena. To prevail, defendants should marshal robust proof of both (1) medical necessity beyond what BOP can reasonably provide and (2) a sentencing balance that now favors release through demonstrated rehabilitation, strong supervision plans, and concrete public-safety assurances. Courts, for their part, should continue to articulate specific, record-based reasons—especially when denying release—in order to secure affirmance under the abuse-of-discretion standard.