Fifth Circuit Reaffirms That § 3553(a) Balancing Alone Can Defeat Compassionate Release Even After Amendment 814

Introduction

In United States v. Clark, No. 24-10020 (5th Cir. Dec. 2, 2024) (per curiam) (unpublished), the Fifth Circuit affirmed the denial of a defendant’s second motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The decision arrives in the wake of the U.S. Sentencing Commission’s 2023 amendments—particularly Amendment 814 to U.S.S.G. § 1B1.13—which expanded the catalog of “extraordinary and compelling reasons,” including for “unusually long sentences.” The panel held that, notwithstanding Amendment 814, a district court’s weighing of the 18 U.S.C. § 3553(a) factors can independently support denial of compassionate release. As a result, the district court’s failure to explicitly discuss Amendment 814 did not require reversal.

The appellant, Telasa Clark, III, proceeding pro se, argued (1) the district court abused its discretion by not addressing Amendment 814 when deciding whether he had shown “extraordinary and compelling reasons,” and (2) the court misweighed the § 3553(a) factors, allegedly in a way that failed to account for the amendment. The Fifth Circuit rejected both arguments, emphasizing that disagreement with how a district court weighs § 3553(a) factors is insufficient to establish abuse of discretion.

Summary of the Opinion

The Fifth Circuit affirmed. It reiterated the three-hurdle framework for compassionate release motions: a movant must (1) show “extraordinary and compelling reasons” justifying a reduction; (2) demonstrate consistency with applicable Sentencing Commission policy statements; and (3) persuade the district court that early release aligns with the § 3553(a) sentencing factors. Although Clark’s second motion invoked Amendment 814’s “unusually long sentence” rationale, the district court denied relief, explaining that—regardless of any threshold showing—the § 3553(a) factors, particularly the seriousness of the offense and the need to protect the public, counseled against release.

On appeal, the panel concluded it need not address whether the district court erred in not discussing Amendment 814 because the § 3553(a) analysis independently supported denial. The court further rejected Clark’s contention that the district court improperly “mirrored” its earlier order, reasoning that the factors on which the court relied—seriousness of the crime and danger to the community—are statutorily grounded and remain relevant to any compassionate-release motion, regardless of Amendment 814.

Case Background

Clark participated in a series of armed robberies between 1999 and 2000 targeting banks, grocery stores, and armored vehicles, using firearms to threaten and subdue victims and stealing more than $150,000. He was indicted on 19 counts but pleaded guilty to one count of bank robbery and aiding and abetting, and two counts of using and carrying a firearm during a crime of violence and aiding and abetting. He received a 600-month prison term and a five-year term of supervised release.

Clark filed his first compassionate-release motion in 2019; after a remand in light of United States v. Shkambi, 993 F.3d 388 (5th Cir. 2021), the district court again denied relief, reasoning there were no extraordinary and compelling reasons and, alternatively, that § 3553(a) factors weighed against release because his conduct was serious and he posed a danger. In 2023, Clark filed a second motion invoking Amendment 814, but the district court denied it in an order that did not explicitly discuss the amendment. Clark appealed.

Analysis

Precedents Cited and Their Influence

United States v. Chambliss, 948 F.3d 691 (5th Cir. 2020): Chambliss supplies the abuse-of-discretion standard of review for denials of compassionate release and states that mere disagreement with a district court’s weighing of the § 3553(a) factors does not establish abuse. The panel relied on Chambliss to reject Clark’s argument that the district court misweighed the factors.
United States v. Rollins, 53 F.4th 353 (5th Cir. 2022): Rollins articulates the three sequential requirements for compassionate release: (1) extraordinary and compelling reasons, (2) consistency with Sentencing Commission policy statements, and (3) consistency with § 3553(a). The Clark panel recited this framework, underscoring that failing at any one step defeats the motion.
United States v. Jackson, 27 F.4th 1088, 1092–93 n.8 (5th Cir. 2022): Jackson confirms that an appellate court may affirm denial of compassionate release solely on the district court’s § 3553(a) analysis, without resolving disputes about “extraordinary and compelling reasons.” Jackson’s principle enabled the Clark panel to bypass the Amendment 814 argument and affirm on § 3553(a) alone.
Ward v. United States, 11 F.4th 354, 360–62 (5th Cir. 2021): Ward likewise supports affirmance where § 3553(a) provides an independent ground for denial, reinforcing the permissibility of resolving compassionate-release appeals on the balancing of statutory sentencing factors.
United States v. Vazquez, 2024 WL 4326542 (5th Cir. Sept. 27, 2024) (per curiam): Vazquez acknowledges Amendment 814’s expansion of enumerated “extraordinary and compelling reasons” in § 1B1.13. Yet Vazquez also affirms denial on § 3553(a) grounds, underscoring the continued primacy of those factors post-Amendment 814. The Clark panel cited Vazquez both to recognize the amendment and to show that § 3553(a) remains dispositive where it weighs against release.
United States v. Garrett, 2024 WL 4708982 (5th Cir. Nov. 7, 2024) (per curiam): Garrett confirms that seriousness of the offense and danger to the community are independently sufficient to deny compassionate release. Garrett’s reasoning maps directly onto the district court’s rationale in Clark.
United States v. Shkambi, 993 F.3d 388 (5th Cir. 2021): Shkambi (relevant to Clark’s earlier remand) held pre-2023 that the then-existing policy statement in § 1B1.13 did not constrain defendant-filed motions. That remand history provides context for Clark’s later invocation of Amendment 814, which now sets the applicable policy framework. The current appeal, however, did not require reconciling Shkambi with the amended policy because § 3553(a) alone supported denial.

Legal Reasoning

The court reviewed for abuse of discretion, a deferential standard that respects district courts’ comparative advantage in weighing sentencing factors. The panel reiterated that compassionate release under § 3582(c)(1)(A) requires:

Extraordinary and compelling reasons warranting a sentence reduction;
Consistency with applicable Sentencing Commission policy statements (now including post-2023 § 1B1.13 and Amendment 814); and
Consistency with the § 3553(a) factors.

Critically, the panel held it need not decide whether the district court erred by not discussing Amendment 814 (the first two hurdles) because the district court’s balancing of § 3553(a) independently justified denial. This aligns with Jackson and Ward. The district court expressly stated it would deny release “even if [Clark] did qualify” on the threshold showing, emphasizing:

The seriousness of Clark’s conduct (§ 3553(a)(2)(A)); and
Clark’s danger to the community (§ 3553(a)(2)(C)).

Clark argued the district court’s latest order improperly “mirrored” an earlier order that predated his Amendment 814 theory. The panel rejected this, reasoning that the core grounds—offense seriousness and danger—are evergreen § 3553(a) considerations. Whether or not Amendment 814 supplies an “extraordinary and compelling” reason, courts must weigh the statutory factors, and those factors can always defeat a motion. The panel emphasized that related considerations Clark criticized (age, time served, and danger) exist independent of Amendment 814 and remain legitimate components of the § 3553(a) inquiry (see § 3553(a)(1) and (2)(C)).

Finally, the panel invoked Chambliss to reiterate that a defendant’s disagreement with the district court’s weighing of § 3553(a) factors does not establish abuse of discretion. The law gives district courts broad latitude to balance history, characteristics, offense gravity, public safety, deterrence, and respect for law.

What Amendment 814 Does—and Why It Didn’t Change the Outcome Here

Amendment 814 (effective November 1, 2023) revised U.S.S.G. § 1B1.13 to apply to defendant-filed compassionate-release motions and expanded the enumerated “extraordinary and compelling reasons.” One notable addition is § 1B1.13(b)(6), permitting courts, in limited circumstances, to treat “unusually long sentences” as an extraordinary and compelling reason—often in interaction with nonretroactive legal changes that would produce a gross disparity between the original sentence and what would likely be imposed today, provided the defendant has served a substantial portion (generally at least ten years) of the sentence.

Yet Amendment 814 did not alter the fundamental structure of § 3582(c)(1)(A): even if a defendant shows an extraordinary and compelling reason and policy-statement consistency, the court must still deny release if the § 3553(a) factors weigh against it. Clark confirms this enduring architecture. The panel accepted that Amendment 814 broadened the first-stage inquiry but held it unnecessary to decide those first steps because § 3553(a) independently barred relief.

Impact and Forward-Looking Implications

Although unpublished and therefore nonprecedential under 5th Cir. R. 47.5, Clark is a cogent illustration of the Fifth Circuit’s post-Amendment 814 approach:

§ 3553(a) remains dispositive: District courts may deny compassionate release strictly on § 3553(a) grounds without resolving whether a movant has established an “extraordinary and compelling reason,” including under Amendment 814’s “unusually long sentence” provision.
Public safety and offense seriousness carry heavy weight: The Fifth Circuit repeatedly affirms denials where district courts ground their decisions in the seriousness of the offense and the defendant’s danger to the community (see Garrett; Chambliss).
Process sufficiency: A district court need not write at length about Amendment 814 if it clearly articulates § 3553(a) reasons that independently warrant denial. Appellate courts will not second-guess the weight the district court assigns to these factors absent clear error or misapplication.
Practical guidance for litigants: Post-Amendment 814, defendants should not assume that identifying an “unusually long sentence” will carry the day. Robust, individualized evidence addressing danger to the community and offense seriousness—such as sustained rehabilitation, reduced recidivism risk, age-related criminological data, disciplinary record, reentry planning, and verified support systems—remains essential. The government, conversely, can successfully oppose release by emphasizing the gravity of the underlying conduct and public-safety considerations.

Complex Concepts Simplified

Compassionate Release (18 U.S.C. § 3582(c)(1)(A)): A statute allowing courts to reduce a term of imprisonment for “extraordinary and compelling reasons,” if such a reduction is consistent with Sentencing Commission policy statements and the § 3553(a) factors favor release.
Amendment 814 / U.S.S.G. § 1B1.13 (2023): The Sentencing Commission’s 2023 update that applies policy guidance to defendant-filed motions and expands the recognized bases for “extraordinary and compelling reasons,” including, in circumscribed circumstances, “unusually long sentences” reflecting nonretroactive changes in law that would create gross disparities if sentenced today.
§ 3553(a) Factors: Statutory sentencing considerations, including the nature and circumstances of the offense; the defendant’s history and characteristics; the need for the sentence to reflect seriousness, promote respect for the law, provide just punishment, deter criminal conduct, protect the public, and provide needed training or treatment; and the need to avoid unwarranted disparities.
Abuse of Discretion: A deferential appellate standard. The appellate court asks whether the district court made a clear error of judgment or applied the wrong legal standard. It does not reweigh factors simply because it might balance them differently.
Per Curiam / Unpublished: A per curiam opinion is issued by the court collectively without a single named author. Unpublished decisions are not binding precedent in the Fifth Circuit but can be persuasive.

Conclusion

United States v. Clark is a clear reaffirmation that, even after Amendment 814’s expansion of “extraordinary and compelling reasons,” the § 3553(a) factors remain an independent and sufficient ground to deny compassionate release. The panel’s reasoning follows a consistent Fifth Circuit line: appellate courts will affirm where district courts reasonably emphasize offense seriousness and public safety, and they will not reverse simply because a movant disputes the weight assigned to those considerations. For practitioners, Clark underscores that Amendment 814 may open the door to threshold eligibility arguments, but the ultimate gatekeeper is still § 3553(a). A successful motion must therefore directly and persuasively address the core concerns of seriousness and danger to the community with individualized, credible evidence.