First Circuit Requires District Courts to Address Rehabilitation—In Combination with Family Circumstances—When Ruling on Compassionate Release under Amended U.S.S.G. §1B1.13

Introduction

In United States v. Duluc-Méndez (1st Cir. Oct. 15, 2025), the First Circuit vacated and remanded a district court’s summary denial of a compassionate-release motion filed under 18 U.S.C. § 3582(c)(1)(A). The appellant, Víctor Miguel Duluc-Méndez (“Duluc”), is serving a 240-month sentence for a carjacking that resulted in death. After serving roughly half of that term, he sought a sentence reduction to act as caregiver for his mother, who suffers from worsening dementia and other health problems. He also presented extensive evidence of post-conviction rehabilitation, including over 1,000 hours of programming, leadership roles, mentoring, and strong endorsements from Bureau of Prisons (BOP) staff and the facility chaplain.

The district court denied the motion in a brief order, finding (1) that the reasons his siblings could not serve as caregivers were “commonplace” and thus not an extraordinary and compelling reason under § 3582(c)(1)(A) and U.S.S.G. § 1B1.13, and (2) that the § 3553(a) factors—referencing his “criminal record”—weighed against release. The order did not mention rehabilitation. On appeal, the First Circuit held that the district court abused its discretion because the record did not show that it considered (a) the defendant’s rehabilitation in combination with his family circumstances when assessing “extraordinary and compelling reasons” under the amended policy statement in U.S.S.G. § 1B1.13, or (b) his rehabilitation as part of the § 3553(a) analysis.

The opinion clarifies that, after the Sentencing Commission’s November 1, 2023 amendments to § 1B1.13, district courts must consider a defendant’s rehabilitation in combination with other circumstances (such as qualifying family circumstances) when evaluating compassionate-release motions. The court further emphasized that judges must address a movant’s central rehabilitation arguments under § 3553(a), and a bare reference to “criminal record” does not suffice when robust rehabilitation evidence is presented.

Summary of the Opinion

The First Circuit vacated the denial of compassionate release and remanded because it could not determine from the district court’s cursory order whether the court had considered two core, legally cognizable arguments:

• Whether the defendant’s post-conviction rehabilitation, combined with his mother’s medical condition and caregiver needs, constituted “extraordinary and compelling reasons” consistent with the Sentencing Commission’s policy statement, U.S.S.G. § 1B1.13 (as amended Nov. 1, 2023).
• Whether, even if such reasons existed, the § 3553(a) factors—including the defendant’s substantial rehabilitation since sentencing—supported a sentence reduction.

The panel relied on Supreme Court and First Circuit precedents requiring district courts to consider nonfrivolous arguments (Concepcion v. United States, 597 U.S. 481 (2022)) and to provide enough explanation to permit meaningful appellate review. It stressed the “holistic” nature of the compassionate-release inquiry, including that rehabilitation may not serve as the sole extraordinary and compelling reason (28 U.S.C. § 994(t)), but may be considered in combination with other circumstances under § 1B1.13(d).

Because the district court (1) denied the motion one day after the government’s opposition (before any defense reply or hearing), (2) echoed the government’s incorrect framing that “rehabilitation alone” is insufficient (without engaging the combination argument), and (3) referenced only “criminal record” under § 3553(a) without confronting the robust rehabilitation showing, the First Circuit concluded that abuse-of-discretion review was “unworkable” and remand was required. The court did not decide whether the family circumstances were, by themselves, “commonplace” and insufficient, nor did it reach the government’s new appellate argument that the mother was not “incapacitated” under § 1B1.13.

Analysis

Precedents Cited and Their Role

• Concepcion v. United States, 597 U.S. 481 (2022): The Supreme Court held that sentencing courts must consider nonfrivolous arguments and relevant factors; they need not accept them but must demonstrate consideration. The First Circuit invoked Concepcion to require the district court to address the defendant’s combination argument (rehabilitation plus family circumstances) and his rehabilitation under § 3553(a).
• First Circuit framework decisions:
  • United States v. Burgos‑Montes, 142 F.4th 48 (1st Cir. 2025): Articulates the three-step compassionate-release inquiry: (1) “extraordinary and compelling reasons,” (2) consistency with policy statements, and (3) § 3553(a) factors.
  • United States v. Saccoccia, 10 F.4th 1 (1st Cir. 2021): Sets abuse-of-discretion review; explains that courts need not mechanically tick off factors but must permit appellate discernment of reasoning.
  • United States v. D’Angelo, 110 F.4th 42 (1st Cir. 2024), and United States v. Gonzalez, 68 F.4th 699 (1st Cir. 2023): Endorse a “holistic” approach to “extraordinary and compelling” reasons, allowing courts to consider a complex of circumstances rather than pigeonholes.
  • United States v. Ruvalcaba, 26 F.4th 14 (1st Cir. 2022): Pre‑2023, courts had broad discretion unconstrained by an applicable policy statement; the 2023 amendments to § 1B1.13 now provide a binding statement for prisoner-initiated motions.
  • United States v. Sepulveda, 34 F.4th 71 (1st Cir. 2022): Rehabilitation alone cannot be an “extraordinary and compelling” reason (codified at 28 U.S.C. § 994(t)), but does not bar consideration of rehabilitation in combination with other factors.
  • United States v. Trenkler, 47 F.4th 42 (1st Cir. 2022): Clarifies the difference between what may be considered within the “extraordinary and compelling” inquiry and what may, by itself, qualify as such.
  • United States v. Texeira‑Nieves, 23 F.4th 48 (1st Cir. 2022): Even when the sentencing judge decides a compassionate-release motion, the court must still address the movant’s significant post-sentencing developments; an abbreviated explanation may suffice, but not silence on central points.
  • United States v. Cruz‑Rivera, 137 F.4th 25 (1st Cir. 2025) and United States v. Mendez, 802 F.3d 93 (1st Cir. 2015): Where the record makes it “impossible to determine” whether the court considered a central argument, abuse-of-discretion review is unworkable and remand is necessary.
  • United States v. Flores‑Nater, 144 F.4th 56 (1st Cir. 2025) and United States v. Colón‑Cordero, 91 F.4th 41 (1st Cir. 2024): A court cannot completely ignore a party’s central argument; some explanation is required to show it was considered.
  • United States v. Quirós‑Morales, 83 F.4th 79 (1st Cir. 2023): Appellate courts ordinarily remand rather than order compassionate release; district courts should apply the standard to the full record in the first instance.
• Fourth Circuit persuasive authority:
  • United States v. Davis, 99 F.4th 647 (4th Cir. 2024): District court abused its discretion in overlooking rehabilitation evidence within the compassionate-release analysis; also underscores the need to address post-sentencing change under § 3553(a).
  • United States v. Malone, 57 F.4th 167 (4th Cir. 2023) (Harris, J., concurring): Appellate courts should rarely direct release; remand is appropriate unless release is the only possible outcome.
• Sentencing Commission Policy Statement (Nov. 1, 2023): U.S.S.G. § 1B1.13 (as amended) now applies to defendant-filed motions and expressly provides that “rehabilitation of the defendant while serving the sentence may be considered in combination with other circumstances” (§ 1B1.13(d)); it also identifies family circumstances as a potential basis (§ 1B1.13(b)(3)).

Legal Reasoning

The First Circuit applied the three-step framework for compassionate release:

1. Extraordinary and compelling reasons (18 U.S.C. § 3582(c)(1)(A)(i)): Courts must take a “holistic” view of the defendant’s circumstances. Rehabilitation cannot be the sole reason (28 U.S.C. § 994(t); U.S.S.G. § 1B1.13(d)), but may be considered in combination with other circumstances, such as family caregiving needs (§ 1B1.13(b)(3)). Duluc’s motion explicitly advanced a combination theory—his mother’s serious decline plus his extensive rehabilitation—which is cognizable under both the statute and the new policy statement. The district court’s order, however, assessed only whether siblings’ inability to help was “convincing,” labeling the obstacles “commonplace.” It did not acknowledge the combination argument or engage with the rehabilitation evidence at all.
2. Consistency with the applicable policy statements (U.S.S.G. § 1B1.13): Because the 2023 amendments made § 1B1.13 applicable to prisoner-initiated motions, the district court needed to evaluate whether the asserted reasons fit within the policy framework, including the allowance to consider rehabilitation “in combination” and the family-circumstances pathway. The order cited § 1B1.13 but did not demonstrate that the court meaningfully applied it to the combination argument.
3. Section 3553(a) factors: Even if a defendant clears steps one and two, a court may deny relief based on § 3553(a). Here, the district court cited § 3553(a) and said only that the defendant’s “criminal record” weighed against release. Given the centrality and strength of the rehabilitation showing—and the decade-long intervening period since sentencing—the First Circuit held the district court was required to engage with the rehabilitation argument. A conclusory reference to “criminal record,” without acknowledgment of the substantial post-sentencing change, prevented meaningful appellate review.

The panel’s concerns were heightened by the rapid sequence of events (denial one day after the government’s opposition, no hearing, and no opportunity for a defense reply), the nuanced and relatively recent legal terrain created by the 2023 guideline amendments, and the order’s close resemblance to the government’s position—which itself addressed only “rehabilitation alone,” not rehabilitation in combination. This combination of factors created a serious risk that the district court overlooked an available and nonfrivolous legal pathway, requiring vacatur and remand.

Importantly, the First Circuit did not decide whether the family circumstances were independently insufficient or whether the mother was “incapacitated” under § 1B1.13; those issues remain for the district court on remand. Nor did the court order release; consistent with Quirós‑Morales, it left the discretionary determination to the district court after proper consideration of the full record.

Impact

The decision has several practical and doctrinal implications in the First Circuit (and persuasive force elsewhere):

• Mandatory consideration of combination arguments: After the 2023 amendments to § 1B1.13, district courts must consider rehabilitation in combination with other asserted grounds (e.g., family caregiving) when evaluating “extraordinary and compelling reasons.” Ignoring a properly presented combination argument is legal error.
• Required engagement with rehabilitation under § 3553(a): Where a movant presents substantial post-sentencing rehabilitation, the court must grapple with that change in circumstances. A terse reference to the underlying offense or “criminal record” is unlikely to suffice, especially after a significant period of incarceration.
• Short, conclusory orders are hazardous: Summary denials, particularly those issued without reply briefing or hearings, risk remand if they fail to address central arguments and evidence. District courts should provide enough explanation to enable appellate review.
• Development of the record on “family circumstances” and “incapacitation”: The case signals that fact-intensive questions—such as whether siblings are truly unavailable or whether a parent is “incapacitated” under § 1B1.13—may warrant evidentiary development. Counsel should be prepared to offer concrete, corroborated details on caregiver availability and the parent’s ability to perform activities of daily living.
• Convergence across circuits: The First Circuit’s approach tracks the Fourth Circuit’s view (Davis) that overlooking rehabilitation is an abuse of discretion. This convergence, coupled with the Commission’s express “combination” language, will likely promote more uniform treatment of rehabilitation in compassionate-release cases.
• Sentencing judge advantage has limits: Although sentencing judges can offer abbreviated analyses when they later consider compassionate release (Texeira‑Nieves), they must still address material changes, such as robust rehabilitation, that post-date the original sentencing.
• Government briefing must engage the combination theory: Arguing “rehabilitation alone” is insufficient does not answer a combination claim. Government oppositions should directly confront whether “rehabilitation plus X” satisfies § 1B1.13 and, if not, why.

Complex Concepts Simplified

• Compassionate release (18 U.S.C. § 3582(c)(1)(A)): A narrow exception allowing courts to reduce a term of imprisonment for “extraordinary and compelling reasons,” consistent with the Sentencing Commission’s policy statement, after considering the § 3553(a) sentencing factors.
• “Extraordinary and compelling reasons”: Not defined by statute, but elaborated in U.S.S.G. § 1B1.13. Examples include serious medical conditions, certain family caregiving needs, and other comparable circumstances. The 2023 amendments clarify that rehabilitation can be considered in combination with other circumstances but cannot, by itself, be the sole reason for reduction.
• U.S.S.G. § 1B1.13 (2023): The Sentencing Commission’s binding policy statement for prisoner-initiated motions. It:
  • Enumerates qualifying reasons (including family circumstances),
  • Allows rehabilitation to be considered “in combination” with other reasons (§ 1B1.13(d)), and
  • Requires that any reduction be consistent with public safety considerations, among other things.
• Family-circumstances pathway: Typically requires that a qualifying family member be incapacitated and that the defendant is the only available caregiver. “Incapacitated” generally means an inability to provide self-care for activities of daily living. Evidence usually includes medical records and detailed affidavits regarding caregiver availability.
• § 3553(a) factors: Sentencing considerations such as the nature and circumstances of the offense; the defendant’s history and characteristics; the need for the sentence to reflect seriousness, deterrence, protection of the public, and rehabilitation; and the need to avoid unwarranted disparities. Post-sentencing rehabilitation is highly relevant to several of these considerations.
• Abuse of discretion standard: Appellate courts defer to district courts’ judgment calls but review legal errors de novo and factual findings for clear error. Failing to consider a nonfrivolous, legally cognizable argument is an abuse of discretion.
• Concepcion’s requirement: A court must consider nonfrivolous arguments presented; it need not accept them, but it cannot ignore them. This applies in sentencing and analogous post-sentencing contexts such as compassionate release.

Conclusion

United States v. Duluc‑Méndez reinforces two post‑2023 guideposts for compassionate‑release adjudication in the First Circuit. First, rehabilitation must be considered when combined with other asserted grounds—such as family caregiving—under U.S.S.G. § 1B1.13. A district court’s failure to acknowledge or engage with a properly raised combination theory is legal error. Second, rehabilitation remains a central component of the § 3553(a) analysis; courts must confront credible, substantial post‑sentencing rehabilitation evidence rather than relying solely on the defendant’s prior “criminal record.”

The decision does not mandate release in Duluc’s case. Instead, it demands a procedurally sound, transparent application of the three‑step framework—one that allows for meaningful appellate review and respects the Sentencing Commission’s updated policy statement. Going forward, district courts in the First Circuit should ensure that orders address the core arguments advanced, particularly combination theories under § 1B1.13 and robust rehabilitation records, to reduce the risk of remand and to promote consistent, principled compassionate‑release decisions.