Compassionate Release After the 2023 Guideline Amendments: Eleventh Circuit Reaffirms that § 3553(a) Alone Can Defeat Relief

Introduction

In United States v. Danny Varela, No. 25-11314 (11th Cir. Nov. 7, 2025) (per curiam) (non-argument calendar) (unpublished), the Eleventh Circuit granted the government’s motion for summary affirmance and upheld the district court’s denial of a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). Proceeding pro se, Varela sought a sentence reduction, invoking the compassionate-release framework as amended by the First Step Act of 2018 and informed by the Sentencing Commission’s 2023 revisions to U.S.S.G. § 1B1.13. The case centers on whether the district court abused its discretion in denying relief based on the § 3553(a) factors without definitively resolving whether “extraordinary and compelling reasons” existed under the newly expanded guideline categories.

The Eleventh Circuit reaffirmed a key principle from its earlier precedents: district courts may deny compassionate release solely on § 3553(a) grounds, and they need not reach the “extraordinary and compelling” inquiry or the public-safety prong if any one required condition is unsatisfied. This reaffirmation comes in the wake of the 2023 amendments to § 1B1.13, which broadened examples of “extraordinary and compelling reasons”—including a new “unusually long sentence” provision and an expanded catch-all—but did not alter the Eleventh Circuit’s sequentially independent prerequisites for relief.

Summary of the Opinion

• The Eleventh Circuit granted the government’s motion for summary affirmance under Groendyke Transp., Inc. v. Davis (406 F.2d 1158 (5th Cir. 1969)), concluding the government’s position was “clearly right as a matter of law.”
• Standard of review: eligibility for a sentence reduction under § 3582(c)(1)(A) is reviewed de novo; denial of relief is reviewed for abuse of discretion (United States v. Giron, 15 F.4th 1343 (11th Cir. 2021)).
• The court reiterated that a district court may deny compassionate release based exclusively on § 3553(a) considerations and need not address the other prongs if one is dispositive (United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021); Giron).
• The district court—through adoption of a magistrate judge’s report and recommendation—provided sufficient analysis under United States v. Cook, 998 F.3d 1180 (11th Cir. 2021), explicitly weighing the seriousness of the offense (involving four deaths) and Varela’s escalating criminal history against his “laudable” rehabilitative efforts.
• The court acknowledged the 2023 amendments to U.S.S.G. § 1B1.13 (including “unusually long sentence” and other enumerated grounds) but held that whether Varela established “extraordinary and compelling reasons” under § 1B1.13(b)(5) or (b)(6) was immaterial given the adverse § 3553(a) balance.
• Result: Affirmed. The district court did not abuse its discretion in denying compassionate release based on § 3553(a). Summary disposition was appropriate.

Analysis

Precedents Cited and Their Influence

• Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969):

  Groendyke provides the standard for summary disposition: it is appropriate when time is of the essence or when one party’s position is clearly correct as a matter of law, leaving no substantial question as to the outcome. The Eleventh Circuit applied this standard to streamline resolution, delaying remaining briefing under 11th Cir. R. 31-1(c). Given the district court’s reasoned reliance on § 3553(a) and well-settled Eleventh Circuit law (Tinker, Giron), summary affirmance was warranted.

• United States v. Puentes, 803 F.3d 597 (11th Cir. 2015):

  Puentes reiterates that district courts lack inherent authority to modify sentences; any modification must be statutorily authorized. This anchors the court’s framing of § 3582(c)(1)(A) as a narrow exception to finality, emphasizing faithful adherence to statutory and guideline constraints.

• First Step Act of 2018, § 603:

  The Act expanded access to compassionate release by enabling defendants to file their own motions. The opinion situates Varela’s motion within this statutory context, later noting how the 2023 guideline amendments now expressly apply to defendant-initiated motions, but do not alter the Eleventh Circuit’s three-condition framework.

• United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021):

  Tinker holds that a district court may address the three requirements—(1) extraordinary and compelling reasons; (2) consistency with § 1B1.13, including danger-to-community considerations; and (3) § 3553(a) factors—in any order, and that failure on any one prong forecloses relief. The Varela panel expressly relies on Tinker’s sequencing and dispositional rule to affirm on § 3553(a) alone.

• United States v. Giron, 15 F.4th 1343 (11th Cir. 2021):

  Giron supplies the standard of review—de novo for eligibility, abuse of discretion for denial—and confirms that denial is proper even if the district court analyzes only one of the three prongs. Varela’s affirmance aligns with Giron’s deferential review of § 3553(a) weighing.

• United States v. Cook, 998 F.3d 1180 (11th Cir. 2021):

  Cook requires a district court to provide enough analysis for meaningful appellate review, without exhaustively discussing every § 3553(a) factor. The magistrate judge’s report—adopted by the district court—satisfied Cook: it recognized Varela’s rehabilitative efforts but explained why the seriousness of the offense (involving four deaths) and his escalating criminal history predominated.

• United States v. Butler, 39 F.4th 1349 (11th Cir. 2022):

  Butler confirms that the weight accorded to each § 3553(a) factor is committed to the district court’s sound discretion. The Varela panel relied on Butler to uphold the district court’s choice to assign greater weight to seriousness, respect for law, and deterrence over rehabilitation.

Legal Reasoning

The court began with the foundational principle that sentence modifications are exceptional and must be authorized by statute. Compassionate release is governed by § 3582(c)(1)(A), which allows a court to reduce a sentence if three conditions are met: (1) the defendant presents “extraordinary and compelling reasons,” (2) the reduction is consistent with U.S.S.G. § 1B1.13—including that the defendant is not a danger to the community per § 3142(g), and (3) the § 3553(a) factors favor reduction. Under Tinker, these conditions are independent and may be addressed in any order; failure on any one disposes of the motion.

Here, the district court chose the § 3553(a) route. Through a magistrate judge’s report and recommendation, the court acknowledged Varela’s “laudable” rehabilitative efforts but concluded that the seriousness of his offense—resulting in four deaths—and his escalating criminal history outweighed mitigation. This approach adhered to Cook by providing adequate reasoning for appellate review and aligned with Butler by exercising discretion in weighing factors like seriousness, respect for the law, and deterrence.

The panel acknowledged the Sentencing Commission’s 2023 amendments to § 1B1.13, which:

• Expressly apply the policy statement to defendant-initiated motions (§ 1B1.13(a));
• Enumerate expanded “extraordinary and compelling” categories, including medical, age, family circumstances, victimization while incarcerated, and an “unusually long sentence” provision permitting consideration of intervening changes in law that would produce a “gross disparity” (§ 1B1.13(b)(1)–(4), (6)); and
• Include an “other reasons” catch-all for circumstances similar in gravity to enumerated examples (§ 1B1.13(b)(5)).

Notwithstanding these expansions, the panel emphasized that the § 3553(a) factors remain an independent and potentially dispositive barrier. It therefore found it “immaterial” whether Varela actually showed extraordinary reasons under the new catch-all or “unusually long sentence” provisions, because the district court reasonably concluded that the § 3553(a) factors did not support release. This reasoning squarely applies Tinker and Giron in the post-amendment landscape: the 2023 changes broaden circumstances that may qualify as extraordinary and compelling, but they do not require relief, and they do not eliminate the district court’s authority to deny based solely on the statutory sentencing factors.

Finally, because the district court’s decision tracked settled Eleventh Circuit law and reflected a permissible exercise of discretion, the panel determined that the government’s position was “clearly right as a matter of law,” justifying summary affirmance under Groendyke.

Impact and Implications

• Reaffirmation post-2023: § 3553(a) remains dispositive. The opinion confirms that after the 2023 amendments to § 1B1.13, district courts in the Eleventh Circuit may deny compassionate release on § 3553(a) grounds alone without reaching “extraordinary and compelling reasons.” This continuity preserves the Tinker framework and underscores that expanded guideline categories do not diminish the centrality of sentencing factors.
• Practical emphasis on offense seriousness and criminal history. The panel’s approval of the district court’s weighting—focusing on multiple deaths and an escalating criminal history—signals that, in serious cases, § 3553(a) will often be determinative notwithstanding rehabilitation or post-sentencing developments.
• Guidance on record sufficiency for district courts. Adoption of a magistrate judge’s detailed report can satisfy Cook’s requirement of sufficient explanation, provided the reasoning enables meaningful appellate review. Explicitly acknowledging mitigation while explaining why other factors predominate is key.
• Limited appellate prospects where § 3553(a) is the fulcrum. Given Butler’s deference to a district court’s weighting of § 3553(a) factors, appellants face an uphill battle challenging denials premised on seriousness, deterrence, and respect for law, especially in cases involving loss of life.
• Interaction with § 1B1.13(b)(6) (“unusually long sentence”). The decision does not define when a sentence is “unusually long” or what constitutes a “gross disparity” due to changes in law. But it makes clear that even if such a disparity exists and qualifies as extraordinary, the court may still deny relief if § 3553(a) counsels against release.
• Use of summary affirmance. The case illustrates that when the district court’s reasoning aligns with well-settled Eleventh Circuit standards, the court of appeals may summarily affirm without full briefing or oral argument, streamlining finality in compassionate-release appeals.

Complex Concepts Simplified

• Compassionate Release (18 U.S.C. § 3582(c)(1)(A)): A narrow statutory exception allowing a court to reduce a lawfully imposed sentence when extraordinary and compelling reasons exist, the reduction is consistent with the Sentencing Commission’s policy statement (§ 1B1.13), and the § 3553(a) sentencing factors support a reduction.
• Three Independent Requirements: A defendant must satisfy all three: (1) extraordinary and compelling reasons; (2) no danger/inconsistency with § 1B1.13; and (3) § 3553(a) factors favor release. Failure on any one defeats the motion (Tinker; Giron).
• 2023 Amendments to U.S.S.G. § 1B1.13: The policy statement now expressly applies to defendant-filed motions and expands enumerated categories (medical, age, family, abuse in custody, unusually long sentence due to changes in law, and a catch-all for similar-gravity reasons). Rehabilitation alone, however, is not an extraordinary and compelling reason under the guidelines.
• § 3553(a) Factors: These statutory factors include the nature and circumstances of the offense; the defendant’s history and characteristics; and the need for the sentence to reflect seriousness, promote respect for law, and deter crime. Courts may assign differing weights to these factors in their discretion (Butler).
• Danger to the Community (§ 3142(g)): When relevant under § 1B1.13, courts consider whether release poses a danger, accounting for the offense’s nature, evidence strength, criminal history, and the seriousness of any potential harm upon release.
• Per Curiam; Non-Argument Calendar; Unpublished: A per curiam decision is issued by the panel collectively. The non-argument calendar indicates resolution without oral argument. “Not for publication” signifies the opinion is non-precedential, though it reflects the court’s application of existing law.
• Summary Affirmance (Groendyke): The court may summarily affirm when one party’s legal position is clearly correct or when delay would effectively deny rights. It expedites resolution without full briefing once the standard is met.
• Standards of Review: Eligibility under § 3582(c)(1)(A) is reviewed de novo. The ultimate denial of relief—particularly the weighing of § 3553(a) factors—is reviewed for abuse of discretion (Giron), a deferential standard.

Conclusion

United States v. Varela reinforces a cornerstone of Eleventh Circuit compassionate-release jurisprudence: even after the Sentencing Commission’s 2023 expansion of “extraordinary and compelling reasons,” district courts may deny relief solely on the basis of the § 3553(a) factors, without resolving whether the defendant’s reasons qualify under § 1B1.13. The district court’s reasoned emphasis on offense seriousness—here, involving four deaths—and criminal history satisfied Cook’s explanatory requirement and fell squarely within Butler’s discretionary range.

For litigants, the decision underscores that the most formidable hurdle in compassionate-release motions remains the § 3553(a) analysis. Even robust evidence of change in law, rehabilitation, or other compelling circumstances will not secure a reduction if the sentencing factors—especially seriousness, respect for law, and deterrence—do not favor early release. For district courts, Varela affirms that concise but specific reasoning, including adoption of a well-articulated magistrate judge’s report, is sufficient. And for appellate practice, it illustrates that where established Eleventh Circuit principles are faithfully applied, summary affirmance is appropriate.

The key takeaway: the 2023 guideline amendments broaden the gateway to “extraordinary and compelling” reasons, but they do not alter the Eleventh Circuit’s rule that § 3553(a) alone can—and often will—decide the outcome of compassionate-release motions.