No Obligation to Reweigh § 3553(a) in Light of Intervening Law: Eleventh Circuit Affirms Denial of Compassionate Release in United States v. Cruz

Introduction

In an unpublished, per curiam decision, the Eleventh Circuit in United States v. Luis Enrique Cruz (No. 24-11309, Oct. 2, 2025) affirmed the denial of a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The case arises from a 1999 spree of violent offenses, including multiple armed robberies, shootings, and carjackings, for which Cruz received a 852-month sentence that included “stacked” 18 U.S.C. § 924(c) terms. Decades later, Cruz argued that changes in law would produce a substantially shorter sentence if he were sentenced today and that this disparity is an “extraordinary and compelling” reason for a sentence reduction under U.S.S.G. § 1B1.13(b)(6).

The key issue on appeal was whether the district court abused its discretion by denying relief based on the 18 U.S.C. § 3553(a) factors and by declining to treat intervening legal changes as part of that factors analysis. The Eleventh Circuit held that district courts may deny compassionate release solely on § 3553(a) grounds and are not required to reweigh those factors to account for intervening changes in sentencing law—even when the asserted “extraordinary and compelling” reason rests on such changes.

Summary of the Opinion

The court affirmed the district court’s denial of Cruz’s § 3582(c)(1)(A) motion. Applying abuse-of-discretion review, the panel concluded:

The district court permissibly denied relief based on the § 3553(a) factors alone, without reaching whether “extraordinary and compelling reasons” existed or whether Cruz remained a danger to the community under U.S.S.G. § 1B1.13.
The district court’s analysis of the nature and circumstances of the offense, Cruz’s history and characteristics (including prior violent crime and recent prison disciplinary infractions), and the need for deterrence, punishment, respect for law, and public protection was sufficiently reasoned and firmly supported by the record.
Nothing in § 3553(a) required the district court to adjust its assessment of the seriousness of the offenses or other factors to account for intervening changes in law or guidelines ranges. In particular, the court rejected the argument that the court had to compare the original sentence to a hypothetical post-change range as part of its § 3553(a) analysis.

Because the § 3553(a) analysis was dispositive, the Eleventh Circuit did not reach the district court’s alternative determinations about danger to the community or the scope of the policy statement in § 1B1.13.

Factual and Procedural Background

In late 1999, Cruz committed a series of violent crimes:

Two armed robberies of Brinks couriers.
Shooting at a motorist “because he just felt like it.”
Fleeing law enforcement, carjacking a van at machine-gun point, driving against traffic and causing collisions, attempting another carjacking, and being apprehended.

He pleaded guilty to multiple counts, including conspiracy and substantive Hobbs Act robberies (18 U.S.C. § 1951), three § 924(c) counts for using a firearm during crimes of violence, two felon-in-possession counts (18 U.S.C. § 922(g)), two possession-of-a-machine-gun counts (18 U.S.C. § 922(o)), and two carjacking-related counts (18 U.S.C. § 2119). He received 852 months, comprising concurrent terms on the non-§ 924(c) counts and 684 months of consecutive, “stacked” § 924(c) sentences (84 months on one count and 300 months on each of the other two). His sentence was affirmed in 2001.

In 2023, Cruz sought compassionate release under § 3582(c)(1)(A), grounded in the contention that changes in law—reflected in the 2023 amendments to U.S.S.G. § 1B1.13, including subsection (b)(6) acknowledging that certain legal changes may produce extraordinary and compelling reasons—would yield a substantially lower sentence if imposed today. The district court denied the motion, emphasizing that the § 3553(a) factors decisively weighed against a reduction, and alternatively finding that a reduction would contravene U.S.S.G. § 1B1.13 and that Cruz remained dangerous.

Detailed Analysis

Precedents and Authorities Cited

United States v. Giron, 15 F.4th 1343 (11th Cir. 2021): Establishes abuse-of-discretion review for § 3582(c)(1)(A) denials. The panel relies on this standard to defer to the district court’s weighing of the record unless legal error, procedural misstep, or clearly erroneous factfinding is shown.
Dillon v. United States, 560 U.S. 817 (2010): Although addressing § 3582(c)(2), Dillon confirms that sentence-modification decisions are discretionary after eligibility is established, and that courts tailor relief in light of § 3553(a). The Eleventh Circuit cites Dillon to underscore district courts’ decisional latitude.
United States v. Harris, 989 F.3d 908 (11th Cir. 2021), and Sloss Indus. Corp. v. Eurisol, 488 F.3d 922 (11th Cir. 2007): Articulate that abuse-of-discretion review gives district courts a “range of choice,” and appellate reversal is improper merely because a different outcome could have been reached.
United States v. Barrington, 648 F.3d 1178 (11th Cir. 2011): Describes abuse-of-discretion parameters: applying incorrect law, using improper procedures, or clearly erroneous factfinding.
United States v. Puentes, 803 F.3d 597 (11th Cir. 2015): Reiterates that courts have no inherent authority to modify sentences; they may act only when a statute or rule authorizes it—setting the structural posture of § 3582(c)(1)(A) motions.
United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021): A cornerstone in compassionate-release jurisprudence within the circuit. Tinker holds that courts may consider the three prerequisites—(1) § 3553(a), (2) extraordinary and compelling reasons, and (3) danger under § 1B1.13—in any order; the absence of any one is dispositive. Cruz squarely applies Tinker: the district court denied on § 3553(a) alone, which ends the analysis.
McKay v. United States, 657 F.3d 1190 (11th Cir. 2011): Permits affirmance on any ground supported by the record, even if different from the district court’s stated rationale. The panel invokes this to affirm based on § 3553(a), without reaching alternative grounds.
United States v. Rosales-Bruno, 789 F.3d 1249 (11th Cir. 2015): Confirms district courts’ broad discretion in how they weigh § 3553(a) factors; there is no prescribed formula for balancing them.
United States v. Cook, 998 F.3d 1180 (11th Cir. 2021): Clarifies that a district court need not address every § 3553(a) factor or every piece of mitigating evidence; it suffices to demonstrate consideration of the relevant factors and to provide enough reasoning for meaningful appellate review.

The opinion also references the U.S. Sentencing Guidelines’ compassionate-release policy statement, U.S.S.G. § 1B1.13, including its “danger to the community” requirement and the 2023 addition at § 1B1.13(b)(6), which allows, in limited circumstances, consideration of changes in law as part of the “extraordinary and compelling” analysis. Notably, the panel affirms without needing to resolve that issue due to the dispositive § 3553(a) ruling.

The Court’s Legal Reasoning

The Eleventh Circuit’s reasoning proceeds in three interlocking steps.

Deference to the district court’s § 3553(a) analysis: The district court carefully recounted the violent nature of Cruz’s offenses; his role in organizing armed robberies; impulsive and gratuitous violence (shooting at a driver “just because”); carjackings at gunpoint, including a machine gun; dangerous flight behavior causing collisions; and his later prison disciplinary infractions (assaulting another inmate and threatening staff). It also weighed his criminal history, including a prior armed robbery. From these facts, the district court concluded that a reduction would not reflect the seriousness of the offenses, promote respect for law, provide just punishment, protect the public, or achieve adequate deterrence. The appellate panel found that this discussion met Cook’s requirement for “enough analysis” and was within the wide discretion recognized by Rosales-Bruno.
No requirement to fold legal changes into § 3553(a): Cruz argued that, because his original sentence was at the low end of the 2000 Guidelines range, the court should assess the seriousness of his offense and overall punishment by reference to what the law would yield today—effectively “re-setting” the § 3553(a) calculus to account for intervening reforms. The Eleventh Circuit rejected this. It held that nothing in § 3553(a) requires district courts to reweigh the statutory factors through the lens of post-sentencing legal changes. Put differently, while legal changes may be considered in determining whether “extraordinary and compelling reasons” exist (a separate prerequisite under U.S.S.G. § 1B1.13(b)(6)), they do not alter the discretionary § 3553(a) balancing, and courts are not obligated to import those changes into the factors analysis.
Tinker’s sequencing rule controls—§ 3553(a) alone is dispositive: Under Tinker, the district court may deny based solely on § 3553(a) if those factors do not support a reduction. That is what happened here. Because the district court’s § 3553(a) analysis suffices to deny relief, neither the “extraordinary and compelling” prong nor the “danger” assessment needed to be reached. The panel also noted that it could affirm on any ground supported by the record, per McKay.

Practical Impact and Doctrinal Significance

Although unpublished and thus nonprecedential, Cruz is a clear application—and a pointed clarification—of Eleventh Circuit compassionate-release doctrine post-2023 Guidelines amendments:

Reinforcement of Tinker’s dispositive sequencing: The decision underscores that § 3553(a) remains a threshold barrier. Even if a defendant can show an “extraordinary and compelling” reason (for example, a significant change in law recognized by § 1B1.13(b)(6)), the district court can deny relief solely because the § 3553(a) factors cut against a reduction.
No duty to reweigh § 3553(a) based on intervening law: Practically, this tempers the reach of § 1B1.13(b)(6) within the Eleventh Circuit. Defendants cannot compel courts to recalibrate the gravity of the offense or the need for deterrence by pointing to how a sentence might look if imposed today. That consideration may be relevant to “extraordinary and compelling reasons,” but not mandatory within § 3553(a).
Appellate deference is substantial: The decision reiterates the forgiving abuse-of-discretion standard. So long as the district court acknowledges the § 3553(a) factors and provides sufficient reasoning grounded in the record, its denial will be difficult to overturn—even if a different judge might have granted relief.
Implications for “stacked” § 924(c) cases and change-of-law claims: Post–First Step Act reforms (which curtailed “stacking” in many circumstances) and the 2023 Guidelines’ recognition of change-in-law disparities do not guarantee relief. Where the underlying conduct is violent and the record shows ongoing disciplinary issues, courts may deny on § 3553(a) grounds without grappling with the legal-change disparity in the factors analysis.

For defense counsel, the takeaway is strategic: success on a compassionate-release motion in the Eleventh Circuit will often turn less on establishing an “extraordinary and compelling” reason and more on persuasively showing that the § 3553(a) factors—particularly public safety, deterrence, and respect for law—now favor a reduction. Robust evidence of sustained rehabilitation, exemplary institutional conduct, programming achievements, and concrete reentry plans may be indispensable in counterbalancing severe offense conduct.

Complex Concepts Simplified

Compassionate Release (§ 3582(c)(1)(A)): A limited mechanism allowing courts to reduce a lawfully imposed sentence when (1) the § 3553(a) factors support a reduction, (2) “extraordinary and compelling reasons” exist (as defined by U.S.S.G. § 1B1.13), and (3) the defendant would not pose a danger to any person or the community. All three must support relief; failure of any is dispositive.
§ 3553(a) Factors: Statutory sentencing considerations, including the nature and seriousness of the offense, the defendant’s history and characteristics, the need for just punishment, deterrence, respect for law, protection of the public, and avoidance of unwarranted disparities. Courts decide how much weight to give each factor.
U.S.S.G. § 1B1.13 and “Danger”: The Sentencing Commission’s policy statement that guides compassionate release. It requires that a reduction not endanger the community and enumerates circumstances that may constitute “extraordinary and compelling reasons,” including, after the 2023 amendments, certain change-of-law scenarios at § 1B1.13(b)(6).
“Stacking” § 924(c) Sentences: Before statutory reforms, multiple § 924(c) convictions in the same case could trigger draconian consecutive mandatory minimums (e.g., 7 years for the first brandishing count and 25 years for each “second or subsequent” count), producing large “stacks.” Later changes limited such stacking in many contexts, creating disparities between sentences imposed before and after the reforms.
Abuse-of-Discretion Review: A deferential appellate standard. An appellate court will not substitute its judgment for the district court’s so long as the lower court applied the correct legal standards, used proper procedures, and made fact findings that are not clearly erroneous.
Affirm on Any Ground: The appellate court may affirm a correct outcome even if the district court’s reasoning differed, provided the record supports the outcome.

Conclusion

United States v. Cruz confirms—and sharpens—the Eleventh Circuit’s approach to compassionate release after the 2023 Sentencing Commission amendments. Two practical rules emerge. First, under Tinker, district courts may deny compassionate release solely on § 3553(a) grounds without reaching “extraordinary and compelling reasons” or “danger.” Second, nothing in § 3553(a) obligates courts to integrate or give effect to intervening legal changes when balancing the statutory factors, even where those changes are invoked as the asserted “extraordinary and compelling” basis for relief.

In concrete terms, Cruz signals that change-of-law arguments (including those addressing § 924(c) stacking disparities, now referenced in § 1B1.13(b)(6)) are not self-executing. They must overcome—or at least fit compatibly within—a holistic § 3553(a) assessment that often pivots on the seriousness of the original misconduct, the defendant’s criminal history, institutional behavior, and public-safety considerations. Appellate courts will defer substantially to district courts’ reasoned balancing of those factors.

For practitioners in the Eleventh Circuit, the opinion underscores the centrality of developing a compelling § 3553(a) narrative supported by concrete, post-sentencing rehabilitation evidence. While legal-change disparities can open the door, it is the § 3553(a) showing that will determine whether the door swings open or remains firmly shut.