Compassionate Release May Be Denied Solely on § 3553(a) Grounds Where the District Court Reaffirms a Reasoned Sentencing Analysis (United States v. Khusanov)

Introduction

In United States v. Khusanov, No. 25-14 (2d Cir. Jan. 5, 2026) (summary order), the Second Circuit affirmed the denial of a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The defendant, Dilshod Khusanov, had pleaded guilty to attempting to provide material support to a foreign terrorist organization, in violation of 18 U.S.C. § 2339B(a)(1), after providing roughly $200–$400 to help fund Akhror Saidakhmetov’s travel to Syria to fight with ISIS.

Khusanov was sentenced pursuant to a Federal Rule of Criminal Procedure 11(c)(1)(C) plea agreement to a below-Guidelines term of 132 months’ imprisonment. About two-and-a-half years later, he sought compassionate release, arguing that “extraordinary and compelling reasons” existed—principally family medical hardship (his wife’s cancer and caregiving needs for their autistic child), harsh confinement conditions, a supervised-release disparity, and rehabilitation—and that the § 3553(a) factors warranted a reduction to time served.

The key appellate issue was not whether Khusanov’s asserted circumstances could qualify as “extraordinary and compelling,” but whether the district court abused its discretion in denying relief based on the § 3553(a) factors, relying in significant part on its original sentencing rationale.

Summary of the Opinion

The Second Circuit affirmed on a narrow and familiar ground: the district court’s § 3553(a) analysis was adequately explained and fell within the range of permissible decisions. Because a district court may deny compassionate release based solely on § 3553(a) considerations, the panel did not separately review the “extraordinary and compelling” analysis. The court emphasized that:

denial may rest on § 3553(a) alone;
district courts may reference and rely on their original sentencing analysis when assessing a later compassionate-release motion; and
an appellate court will not find abuse of discretion merely because the defendant disagrees with how the district court balanced the factors.

The panel also rejected Khusanov’s reliance on out-of-circuit cases, distinguishing them on the adequacy of the district court’s explanation and, in one instance, on the presence of a significant Guidelines amendment not applicable here.

Analysis

Precedents Cited

1) Standard of review and the district court’s discretion

United States v. Halvon, 26 F.4th 566 (2d Cir. 2022): Cited for the governing standard—denial of compassionate release is reviewed for abuse of discretion, while statutory interpretation is reviewed de novo. The panel also used Halvon to underscore that disagreement with the district court’s weighing of § 3553(a) is typically insufficient to show abuse.
United States v. Keitt, 21 F.4th 67 (2d Cir. 2021) (quoting United States v. Saladino, 7 F.4th 120 (2d Cir. 2021)): Keitt supplies the abuse-of-discretion framework and, critically, the rule that a district court may deny compassionate release on § 3553(a) grounds without reaching “extraordinary and compelling reasons.” That principle is the structural backbone of the Second Circuit’s disposition here.
United States v. Jones, 17 F.4th 371 (2d Cir. 2021): Cited for the proposition that once § 3553(a) independently supports denial, the court of appeals need not address the “extraordinary and compelling reasons” analysis. The panel followed that route in Khusanov.

2) Sufficiency of explanation and reliance on prior sentencing reasoning

Chavez-Meza v. United States, 585 U.S. 109 (2018): The court relied on Chavez-Meza for two interrelated points: (i) a judge may consider and incorporate the original sentencing rationale when later modifying—or refusing to modify—a sentence; and (ii) the explanation need only be sufficient to allow meaningful appellate review, so long as the record reflects a reasoned basis. In effect, Chavez-Meza supports the panel’s conclusion that the district court’s reaffirmation of its earlier § 3553(a) analysis was permissible.
United States v. Williams, 102 F.4th 618 (2d Cir. 2024) (quoting United States v. Smith, 982 F.3d 106 (2d Cir. 2020)): These cases provide the presumption that sentencing judges consider all relevant § 3553(a) factors and arguments unless the record indicates otherwise, and that courts need not “mechanically march through” each factor. The panel used these principles to reject the claim that the district court failed to reconsider the § 3553(a) factors in light of changed circumstances; the court’s explanation, tied to the prior sentencing and addressing the defendant’s principal arguments, was enough.

3) “Mere disagreement” with balancing and out-of-circuit comparisons

United States v. Chambliss, 948 F.3d 691 (5th Cir. 2020): Quoted (via Halvon) for the proposition that mere disagreement with the balancing of § 3553(a) does not demonstrate abuse of discretion—reinforcing the deference afforded to district courts in compassionate-release decisions.
United States v. Malone, 57 F.4th 167 (4th Cir. 2023) and United States v. Duluc-Méndez, 156 F.4th 55 (1st Cir. 2025): Cited because Khusanov invoked them, but the panel distinguished them. In Khusanov, the district court provided a more detailed § 3553(a) explanation than the district courts at issue in those cases (as characterized by the Second Circuit).
United States v. Davis, 99 F.4th 647 (4th Cir. 2024): Distinguished because that case involved a Guidelines amendment that would have cut the Guidelines range in half—an intervening legal change with obvious § 3553(a) relevance not present in Khusanov’s case.

4) District court decisions referenced (contextual grounding)

United States v. Khusanov, No. 17-CR-475, 2022 WL 3228270 (E.D.N.Y. Aug. 10, 2022) and United States v. Khusanov, No. 17-CR-475, 2024 WL 5046745 (E.D.N.Y. Dec. 9, 2024): The Second Circuit treated these as the operative sentencing and compassionate-release decisions. The district court’s original balancing—seriousness/deterrence versus mitigating characteristics and cooperation—was reused as the anchor for denying compassionate release.
United States v. Davis, No. 08-CR-332, 2010 WL 1221709 (E.D.N.Y. Mar. 29, 2010): Cited (in the procedural history) concerning the requirement of “justifiable reasons” when accepting a Rule 11(c)(1)(C) plea agreement calling for a below-Guidelines sentence, alongside U.S.S.G. § 6B1.2.

Legal Reasoning

The dispositive ground was § 3553(a), not “extraordinary and compelling reasons.” The panel applied Second Circuit doctrine that compassionate release may be denied solely on § 3553(a) grounds. This sequencing matters: even if a defendant presents powerful humanitarian facts, relief remains discretionary if the sentencing purposes—such as deterrence, protection of the public, and offense seriousness—counsel against early release.
The district court’s explanation was deemed adequate. The panel credited the district court for (i) identifying the two § 3553(a)-linked arguments Khusanov pressed (his asserted motivation and the sufficiency of time served), (ii) explaining why it rejected them (including the lack of evidence that funds were directed to an anti-Assad effort), and (iii) explicitly reaffirming its prior sentencing analysis. Under Chavez-Meza and the Second Circuit’s presumption of consideration, that was enough for meaningful appellate review.
Reliance on the original sentencing calculus was permissible. A common compassionate-release argument is that “circumstances changed,” requiring a full reweighing. The panel’s approach indicates that changed circumstances do not, by themselves, compel a different outcome; rather, the district court must consider the motion and articulate a reasoned basis. Here, reaffirming the original § 3553(a) assessment—combined with some motion-specific discussion—fell within permissible decisionmaking.
Appellate deference controlled the outcome. The panel framed the appeal as an attempt to relitigate balancing. Under the abuse-of-discretion standard, the court will not substitute its judgment for the district court’s as long as the decision is reasoned and within the permissible range.

Impact

Although the disposition is a nonprecedential “summary order,” it is practically instructive in several ways consistent with binding Second Circuit doctrine:

§ 3553(a) remains a strong gatekeeper in compassionate-release litigation. Defendants who focus primarily on “extraordinary and compelling reasons” still face a separate—and often decisive—sentencing-purpose inquiry.
District courts can efficiently deny relief by anchoring to the original sentencing record. Khusanov reinforces that courts may adopt and reaffirm prior § 3553(a) reasoning, rather than producing a factor-by-factor rewrite, so long as the explanation permits appellate review and engages the defendant’s principal arguments.
Out-of-circuit “insufficient explanation” reversals will have limited traction where the district court explains itself. The panel’s distinctions suggest that defendants relying on cases like United States v. Malone or United States v. Duluc-Méndez must show similarly thin reasoning in the record—otherwise, those cases will be treated as inapposite.
Guidelines amendments and major legal changes remain the most persuasive “changed circumstances.” The panel’s distinction of United States v. Davis (4th Cir. 2024) signals that intervening legal developments affecting the Guidelines range may carry materially different weight under § 3553(a) than personal hardship alone.

Complex Concepts Simplified

Compassionate release (18 U.S.C. § 3582(c)(1)(A)): A statutory mechanism allowing a court to reduce an already-imposed federal sentence in limited circumstances. Typically, the court asks whether (1) the defendant has met procedural prerequisites (including administrative exhaustion), (2) “extraordinary and compelling reasons” justify a reduction, and (3) the § 3553(a) sentencing factors support a reduction. Any one of these can be dispositive against the defendant, especially § 3553(a).
Section 3553(a) factors: The core sentencing considerations Congress requires courts to weigh, including: seriousness of the offense, respect for the law, just punishment, deterrence, protection of the public, rehabilitation, and avoidance of unwarranted disparities. In compassionate release, these factors operate as a “second look” at whether early release fits the purposes of sentencing.
Abuse of discretion: A deferential appellate standard. The court of appeals does not ask whether it would have decided differently, but whether the district court made a legal error, clearly misread the facts, or made a decision outside the permissible range.
Rule 11(c)(1)(C) plea agreement: A guilty plea in which the parties agree to a specific sentence (or sentencing range). If the judge accepts the agreement, the sentence becomes binding as part of the plea disposition—though later statutory mechanisms (like compassionate release) can still be invoked.
U.S.S.G. § 1B1.13 and “extraordinary and compelling reasons”: A Sentencing Guidelines policy statement addressing compassionate release. Khusanov argued the district court erred in treating § 1B1.13 factors as nonbinding and in applying them. The Second Circuit did not reach those arguments because it affirmed solely on § 3553(a) grounds.

Conclusion

United States v. Khusanov affirms a denial of compassionate release on the straightforward basis that the district court adequately explained—and permissibly reaffirmed—its § 3553(a) sentencing analysis. The decision illustrates a recurring practical rule in compassionate-release litigation: even substantial personal hardship and post-sentencing rehabilitation will not yield relief if the district court reasonably concludes that the seriousness of the offense, deterrence, and other sentencing purposes still require the original term. As a result, future motions in the Second Circuit must be built not only around “extraordinary and compelling reasons,” but also around a persuasive, concrete showing that the § 3553(a) balance has genuinely shifted.

Note: This Second Circuit disposition is a “summary order” and “do[es] not have precedential effect,” though it may be cited in accordance with Fed. R. App. P. 32.1 and Second Circuit Local Rule 32.1.1.