United States v. Williams: Evidentiary Demands for “Extraordinary and Compelling” Medical Circumstances in Compassionate Release

I. Introduction

In United States v. Troy H. Williams, No. 25-3241 (6th Cir. Dec. 12, 2025), the Sixth Circuit addressed when alleged inadequacies in prison medical care rise to the level of “extraordinary and compelling reasons” warranting compassionate release under 18 U.S.C. § 3582(c)(1)(A), in light of the Sentencing Commission’s recently revised policy statement at U.S.S.G. § 1B1.13(b)(1)(C).

Troy Williams, serving a 198‑month sentence for serious drug, firearm, and money-laundering offenses, suffers from thrombophilia and recurrent deep vein thrombosis—conditions that significantly increase the risk of dangerous blood clots. He argued that after a transfer within the Bureau of Prisons (BOP), his new facility (FCI Coleman) was not testing his blood frequently enough and was inconsistently providing his warfarin medication, thereby placing him at risk of serious harm. On that basis, he sought compassionate release on the theory that his medical condition and its allegedly inadequate management met the “extraordinary and compelling” standard in § 3582(c)(1)(A), as fleshed out by § 1B1.13(b)(1)(C).

The district court denied relief, holding that Williams had not shown that his treatment at FCI Coleman was so deficient as to expose him to a serious risk of health deterioration or death, and that even if he had, the § 3553(a) factors would not favor release. Williams appealed, challenging both the district court’s assessment of his medical circumstances and its weighing of the sentencing factors.

The Sixth Circuit affirmed on narrow grounds: it held that the district court did not clearly err in its factual finding that FCI Coleman was adequately managing Williams’s condition, and therefore Williams failed to establish “extraordinary and compelling” reasons under § 3582(c)(1)(A) and § 1B1.13(b)(1)(C). Without that threshold showing, the court had no need to engage the § 3553(a) analysis.

As a precedential opinion, Williams is important for several reasons:

It applies the post‑amendment version of U.S.S.G. § 1B1.13(b)(1)(C) in the medical‑care context.
It clarifies the evidence needed to show inadequate medical treatment that puts a defendant “at risk” of serious deterioration in health or death.
It reinforces the deferential “clear error” standard governing appellate review of district courts’ compassionate-release factfinding.
It reaffirms that unchanged factual circumstances known at sentencing generally cannot be repackaged as “extraordinary and compelling” absent a material change.

II. Summary of the Opinion

A. Factual Background

In 2015, Williams pleaded guilty in the Northern District of Ohio to:

Conspiracy to distribute cocaine, 21 U.S.C. §§ 841(a)(1), (b)(1)(A), 846;
Possession of heroin with intent to distribute, 21 U.S.C. §§ 841(a)(1), (b)(1)(B);
Felon in possession of a firearm, 18 U.S.C. § 922(g); and
Three counts of money laundering, 18 U.S.C. § 1957.

Pursuant to a plea agreement, he received a sentence of 198 months’ imprisonment, substantially below the Guidelines range of 262–327 months, followed by ten years of supervised release.

At the time of sentencing, Williams already suffered from thrombophilia and recurrent deep vein thrombosis. Both conditions are serious: thrombophilia heightens the risk of blood clots, and deep vein thrombosis involves clots in deep veins that can lead to pulmonary embolism (a life‑threatening clot in the lungs). To manage this, he takes warfarin, a blood thinner that requires periodic blood testing to ensure dosing is safe and effective.

Because of his complex medical needs, the BOP classified Williams as a “Care Level 3” inmate, indicating a “complex” condition that requires “frequent clinical contacts” to prevent complications or hospitalizations. Initially housed at FCI Allenwood, he was later transferred to FCI Coleman.

B. The Compassionate Release Motion

In 2024, roughly a decade after his sentencing, Williams—first pro se, then with counsel—moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A). He asserted:

That FCI Coleman was failing to test his blood frequently enough to manage his warfarin dosage;
That periodic lockdowns interfered with his access to blood testing and treatment;
That he was not consistently receiving his warfarin medication;
That these alleged deficiencies placed him at heightened risk of clots and associated complications, thereby satisfying U.S.S.G. § 1B1.13(b)(1)(C); and
That the § 3553(a) factors favored early release in light of rehabilitation, better medical care available in the community, a strong support network, significant time served, and a lengthy term of forthcoming supervised release.

The district court denied the motion. It acknowledged occasional “isolated” delays but found that the BOP’s overall medical care was not “so deficient as to warrant intervention” and thus did not present “extraordinary and compelling” reasons for release. As an alternative holding, it also found that the § 3553(a) factors did not support reducing the sentence.

Williams appealed, challenging:

The district court’s conclusion that his medical circumstances were not “extraordinary and compelling,” and
The court’s application of the § 3553(a) factors.

C. The Sixth Circuit’s Decision

The Sixth Circuit affirmed. Applying its established three-part framework and standards of review, the court:

Reiterated the three criteria for § 3582(c)(1)(A) relief. A defendant must show:
- (1) “extraordinary and compelling reasons” for release;
- (2) consistency with applicable Sentencing Commission policy statements; and
- (3) that the § 3553(a) sentencing factors favor a reduction.
Held that U.S.S.G. § 1B1.13(b)(1)(C) governed Williams’s medical‑care claim. That provision recognizes extraordinary and compelling reasons where:
[T]he defendant is suffering from a medical condition that requires long-term or specialized medical care that is not being provided and without which the defendant is at risk of serious deterioration in health or death.
The court distilled this into a three‑part test for the medical‑care provision:
- A qualifying medical condition requiring long‑term or specialized care;
- A failure to provide that needed care; and
- As a result, an actual “risk of serious deterioration in health or death.”
Reaffirmed that unchanged factual circumstances known at sentencing cannot, standing alone, be “extraordinary and compelling.” Relying on United States v. Hunter, 12 F.4th 555, 569 (6th Cir. 2021), the court emphasized that Williams could not rely simply on his long‑standing thrombophilia diagnosis; instead, he had to show that conditions had changed—specifically, that current care was inadequate and created a serious risk.
Reviewed the district court’s factual findings for clear error. The court examined the medical records and a declaration from FCI Coleman’s Clinical Director, Dr. Kendes Archer—the only expert testimony in the record—and held that the district court did not clearly err in finding that:
- Williams’s condition was “stable and can be fully managed” at FCI Coleman;
- He was receiving ongoing treatment, including blood testing and warfarin;
- “Isolated” delays or slightly longer intervals between tests (including some two-month gaps) did not demonstrate a serious risk of health deterioration;
- Reports of a single documented lockdown‑related delay and an older third‑party investigation into conditions at FCI Coleman did not outweigh the facility’s medical records and Dr. Archer’s declaration; and
- Allegations that warfarin was not being given regularly lacked evidentiary support in the records.
Affirmed on the threshold ground that no “extraordinary and compelling” reasons were shown. Following United States v. Tomes, 990 F.3d 500 (6th Cir. 2021), the panel held that the failure to meet the first prong of the compassionate‑release test was sufficient to affirm, making it unnecessary to reach the § 3553(a) analysis.

The court thus held that the district court did not abuse its discretion in denying the motion, because its factual determination—that Williams’s medical care did not place him at risk of serious deterioration or death—was not clearly erroneous.

III. Detailed Analysis

A. The Legal Framework and Statutory Context

1. Compassionate Release Under 18 U.S.C. § 3582(c)(1)(A)

Section 3582(c)(1)(A), particularly after the First Step Act of 2018, permits courts to reduce an imposed term of imprisonment where:

Extraordinary and compelling reasons warrant a reduction;
The reduction is consistent with applicable policy statements issued by the Sentencing Commission; and
The court, after considering the § 3553(a) factors, finds that the defendant is suitable for release.

Historically, the BOP controlled access to compassionate release by being the sole gatekeeper for filing motions. The First Step Act allowed defendants themselves to file motions after exhausting administrative remedies. That reform, in turn, elevated questions about:

What counts as “extraordinary and compelling reasons,” and
How binding the Sentencing Commission’s policy statement at U.S.S.G. § 1B1.13 is when defendants, not the BOP, initiate motions.

Within the Sixth Circuit, this evolution has produced a substantial line of cases, several of which the Williams panel cites and applies.

2. The Role of the Sentencing Commission’s Policy Statement – § 1B1.13

Under 28 U.S.C. § 994(t), Congress directed the Sentencing Commission to “describe what should be considered extraordinary and compelling reasons for sentence reduction.” The Commission’s policy statement at U.S.S.G. § 1B1.13 fulfills that role.

Before the Commission updated § 1B1.13 in 2023, several circuits—including the Sixth—had held that the then‑existing version was not “applicable” to defendant‑filed motions and thus did not constrain a district court’s judgment about what might be “extraordinary and compelling.” That regime was shaped in the Sixth Circuit by cases like United States v. Jones, 980 F.3d 1098 (6th Cir. 2020).

With the 2023 amendments, however, § 1B1.13 was revised expressly to encompass defendant‑initiated motions, once again providing a comprehensive and “applicable” framework. In United States v. Washington, 122 F.4th 264, 266–67 (6th Cir. 2024), the Sixth Circuit acknowledged that these new provisions now govern the analysis of compassionate-release motions in the circuit.

Williams proceeds on that premise and specifically invokes the medical‑care provision in § 1B1.13(b)(1)(C).

3. U.S.S.G. § 1B1.13(b)(1)(C): Medical Conditions and Inadequate Care

The heart of this case is the Commission’s recognition that extraordinary and compelling reasons exist when:

Extraordinary and compelling reasons exist when the defendant is suffering from a medical condition that requires long-term or specialized medical care that is not being provided and without which the defendant is at risk of serious deterioration in health or death.

The Williams panel states the elements succinctly:

The defendant suffers from a medical condition requiring long‑term or specialized care;
The needed care is not being provided; and
As a result, the defendant is “at risk” of serious deterioration in health or death.

This case does not dispute that thrombophilia and recurrent DVT are serious medical conditions requiring ongoing and specialized management. The controversy lies in elements (2) and (3): whether care is actually deficient and whether that deficiency creates the requisite risk of serious deterioration or death.

B. Precedents Cited and Their Influence

1. McCall v. United States, 56 F.4th 1048 (6th Cir. 2022) (en banc)

McCall—an en banc decision—provides the overarching structure for compassionate‑release adjudication in the Sixth Circuit. The Williams panel quotes McCall for the three‑part framework:

Extraordinary and compelling reasons;
Consistency with applicable policy statements;
Favorable § 3553(a) analysis.

Although McCall itself dealt primarily with issues like non‑retroactive changes in sentencing law, its core contribution here is to reinforce that all three criteria must be satisfied and that district courts may deny relief at any step. Williams uses that framework to end the analysis after step one.

2. United States v. Washington, 122 F.4th 264 (6th Cir. 2024)

Washington is cited for the proposition that courts must look to “applicable policy statements from the Sentencing Commission” to interpret “extraordinary and compelling reasons” under § 3582(c)(1)(A). After the 2023 amendments, § 1B1.13 is again such an “applicable” policy statement for all motions.

By citing Washington, the Williams panel signals:

That the 2023 version of § 1B1.13 now binds courts in the Sixth Circuit when assessing what is “extraordinary and compelling”; and
That the medical‑care category in § 1B1.13(b)(1)(C) supplies both the elements and the limits of Williams’s theory of relief.

3. United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020)

Ruffin establishes that the denial of compassionate release is reviewed for abuse of discretion. Within that overarching standard, legal questions are reviewed de novo, factual findings for clear error, and the ultimate § 3553(a) judgment for abuse of discretion.

Williams relies on this framework and then, following Jones, details the sub‑components:

Legal interpretations – de novo;
Factfinding – clear error;
Balancing of § 3553(a) factors – abuse of discretion.

This separation of functions is central to the panel’s deference to the district court’s assessment of Williams’s medical records and Dr. Archer’s declaration.

4. United States v. Jones, 980 F.3d 1098 (6th Cir. 2020)

Jones is cited primarily for the standard of review components—particularly the notion that appellate courts review factual findings for clear error and the § 3553(a) analysis for abuse of discretion. Although Jones originally had a broader effect (allowing courts more independence from § 1B1.13 before the 2023 amendments), in Williams it functions as a technical procedural precedent governing how appellate courts scrutinize district court decisions.

5. United States v. Tomes, 990 F.3d 500 (6th Cir. 2021)

Tomes is invoked for a narrow but important procedural point: a court may deny a compassionate‑release motion if the defendant fails at any one of the three required criteria, without addressing the others. The Williams panel leans on Tomes to affirm solely on the ground that Williams did not establish extraordinary and compelling reasons, thus avoiding the need to weigh the § 3553(a) factors.

6. United States v. Hunter, 12 F.4th 555 (6th Cir. 2021)

Hunter is cited for the principle that unchanged factual circumstances known at sentencing generally cannot qualify as “extraordinary and compelling” reasons later. In Hunter, the court addressed issues such as non‑retroactive changes to sentencing law and clarified that features baked into the original sentence cannot ordinarily be relitigated as “extraordinary” circumstances.

In Williams, this principle plays a limiting role. Williams’s thrombophilia and recurrent DVT were fully known at the time of sentencing; those diagnoses alone thus cannot form the basis for compassionate release. He must instead show a new development—here, alleged inadequacies in the treatment of that condition at FCI Coleman that put him at a serious new risk.

By citing Hunter, the panel:

Confirms that chronic conditions known at sentencing require some material post‑sentencing change in circumstances (e.g., deterioration, denial of care, new complications) to become “extraordinary and compelling”; and
Clarifies that Williams’s case turns on his treatment (and alleged lack thereof) rather than on the mere existence of his medical condition.

C. The Court’s Legal Reasoning

1. Defining “Extraordinary and Compelling” in the Medical‑Care Context

The panel begins by acknowledging that § 3582 itself does not define “extraordinary and compelling,” and that Congress delegated that definitional task to the Sentencing Commission under 28 U.S.C. § 994(t). Therefore, it is the Commission’s policy statement—here, § 1B1.13(b)(1)(C)—that supplies the governing rule.

The panel expressly adopts the three‑part structure for medical‑care‑based claims:

Qualifying condition: The defendant must have a condition requiring “long-term or specialized medical care.”
Non‑provision of care: That care must “not [be] provided.”
Resulting risk: Without that care, the defendant must be “at risk of serious deterioration in health or death.”

Applying Hunter, the panel holds that conditions known at sentencing cannot themselves constitute the extraordinary and compelling reason. Williams’s thrombophilia was long-standing, so he “prudently” did not rely on the diagnosis alone. Instead, he argued:

[H]e is “at risk” of deterioration or death from the alleged lack of adequate treatment at FCI Coleman.

In short, the legal question under § 1B1.13(b)(1)(C) is whether the alleged inadequacy of care at FCI Coleman places Williams at an actual, serious, medically supported risk—not whether thrombophilia as such is serious (it is), or whether medical care could be better outside prison (it likely could).

2. Standard of Review: Clear Error and Its Consequences

A central feature of the opinion is its insistence on properly applying the clear error standard of review to the district court’s factual findings. The panel reaffirms that:

Whether a given medical regimen is adequate in fact, and whether it places a defendant at a particular level of risk, are largely factual determinations grounded in medical evidence; and
Appellate courts will not disturb those findings unless the district court clearly erred—that is, unless the reviewing court is left with a firm conviction that a mistake has been made.

This deference substantially shapes the outcome. The panel does not re‑weigh the evidence; it asks whether the district court’s view of the record was a permissible one. Because the district court relied heavily on detailed medical records and the declaration of FCI Coleman’s Clinical Director, and because there was no countervailing expert testimony, the court concluded that there was no clear error.

3. Evaluation of the Medical Evidence and Alleged Deficiencies

The panel methodically addresses each of Williams’s factual contentions.

a. Frequency of Blood Testing

Williams argued that FCI Coleman failed to test his blood frequently enough to manage his warfarin safely. He relied on an online medical resource recommending at least monthly blood tests for warfarin patients. His medical records, he claimed, showed testing gaps of roughly two months.

The court did not dispute that frequent testing is advisable, but emphasized key gaps in the evidence:

The website did not establish whether monthly testing is the minimum medically acceptable standard or merely a best practice.
There was no expert testimony linking occasional longer intervals between tests to a medically significant risk of serious deterioration or death.
Williams’s own lab results during the longer intervals still reflected acceptable blood‑clotting times, and his doctors did not change his warfarin dosage—suggesting that, in practice, his condition was stable despite less‑than‑monthly testing.

On that record, the district court found that the frequency of testing did not present a serious health risk. The Sixth Circuit held that this conclusion was not clearly erroneous. The opinion implicitly stands for the proposition that generalized, non‑contextual medical guidance (especially from the internet) cannot, by itself, satisfy § 1B1.13(b)(1)(C) without:

Expert medical testimony explaining why a given deviation is significant for the particular patient, and
Evidence that the deviation actually elevates the risk of serious deterioration or death.

b. Lockdowns and Access to Care

Williams next argued that frequent lockdowns at FCI Coleman prevented him from receiving adequate medical care. He cited:

A medical note documenting a canceled blood test due to “continuous lock downs,” and
A third‑party investigation reporting that lockdowns at FCI Coleman interfered with medical services.

The court acknowledged that the third‑party report was troubling, but emphasized:

Williams’s extensive medical records revealed only one documented instance in which a lockdown interfered with his care.
The third‑party report was more than two years old and not specific to Williams.
Dr. Archer’s declaration directly stated that Williams’s condition was stable and could be fully managed at FCI Coleman.

The panel held that the district court did not clearly err in giving greater weight to:

Williams’s individualized medical records, and
The on‑the‑record expert opinion of his facility’s Clinical Director,

than to a generalized, time‑lagged investigative report.

c. Alleged Inconsistent Delivery of Warfarin

Williams claimed that, after his transfer to FCI Coleman, he was not consistently receiving his warfarin. This allegation, if proved, could well implicate a serious risk of health deterioration, because warfarin interruptions pose a known risk of clot formation.

However, the district court found, and the panel agreed, that:

The claim was not supported by the medical records or other evidence in the record; and
Given the “threadbare evidence,” the district court acted within its discretion in declining to credit this allegation.

In other words, this potentially powerful argument failed not because it was legally irrelevant, but because it was not factually substantiated.

4. The Role of Expert Testimony and Documentary Evidence

A recurring theme in the opinion is the centrality of credible, individualized medical evidence. The court repeatedly underscores that:

Dr. Archer’s declaration was the only expert medical testimony in the record;
The detailed medical records demonstrated ongoing treatment, stability of condition, and acceptable lab values over time; and
No contrary expert evidence was presented to contest these conclusions.

In that evidentiary context, the district court was entitled to credit the BOP’s expert and records over:

Generalized internet medical advice;
A dated third‑party investigation not specific to Williams; and
Unsupported allegations in briefing.

The panel thus sends an important signal: compassionate-release motions based on medical inadequacy must be supported by robust, case‑specific medical evidence, ideally including expert opinion or clear documentary corroboration. General health‑care critiques and unspecific reports about systemic conditions at a prison, while relevant background, will not ordinarily suffice to meet the defendant’s burden under § 1B1.13(b)(1)(C).

5. Disposition at Step One: No “Extraordinary and Compelling” Showing

Because the court held that Williams had not shown a failure of care or a resulting serious risk of health deterioration, he necessarily failed the § 1B1.13(b)(1)(C) test. Invoking Tomes, the panel concluded that this failure at the “extraordinary and compelling” step was dispositive. It therefore did not reach:

Whether the policy statement’s other provisions were satisfied, or
Whether the § 3553(a) factors would support a reduction.

The ultimate holding is narrow but clear: On this record, the district court did not clearly err in finding that Williams’s medical care did not satisfy § 1B1.13(b)(1)(C), and so the denial of compassionate release was not an abuse of discretion.

D. Impact and Implications

1. Clarifying the Medical‑Care Provision of § 1B1.13(b)(1)(C)

Williams offers the first clear, published Sixth Circuit application (in medical‑care terms) of the revised § 1B1.13(b)(1)(C). The opinion articulates and operationalizes the three elements required for a successful claim:

A serious, long‑term or specialized medical condition;
Actual non‑provision of necessary care; and
A medically grounded, non‑speculative risk of serious deterioration or death as a result.

The case demonstrates that:

Seriousness of the diagnosis alone is insufficient. Many incarcerated individuals have serious conditions. What matters is whether the current treatment regime is materially deficient and dangerous compared to accepted standards of care.
Speculation about risk is not enough. Defendants must bridge the gap between theoretical risk and an individualized, evidence‑based showing that they are actually at risk of grave harm given their current care.
The existence of possible better care in the community is not, by itself, dispositive. Compassionate release is not a device for optimal health‑care matching; it is a remedy for extraordinary and compelling situations, which requires a much higher threshold.

2. Evidentiary Demands on Defendants and Counsel

The opinion has significant practical implications for how defense counsel structure and support compassionate‑release motions based on medical inadequacy:

Expert evidence is highly valuable, if not functionally necessary. The BOP can and often will submit declarations from prison medical staff. Without countervailing expert testimony, the court is likely to credit those declarations, especially when supported by medical records.
Medical records must be mined carefully. Counsel should highlight:
- Gaps in treatment;
- Abnormal lab results;
- Documented complaints of pain or symptoms; and
- Any internal notes expressing concern about delayed care or unavailable resources.
In Williams, the records instead largely showed stability and consistent treatment, undermining the claim of inadequacy.
General medical guidance and non‑individualized reports are insufficient by themselves. Websites, guidelines, investigative reports, and news stories may set the stage but will not, without more, demonstrate that this particular inmate is at risk of serious deterioration or death under current conditions.

3. Deference to District Courts in Fact‑Intensive Medical Assessments

By emphasizing the clear‑error standard and affirming reliance on prison medical records and expert declarations, the opinion strengthens the deference given to district courts in medically complex cases. This suggests that:

Careful district court fact‑finding—grounded in the record and explained in a reasoned opinion—will often be insulated from reversal.
On appeal, defendants face a high hurdle in overturning such determinations; they must show not merely that another view of the evidence was possible, but that the lower court’s view was clearly mistaken.

This reinforces the importance of building a thorough record—and making the strongest factual presentation—at the district court level.

4. Continuing Vitality of Hunter for Known Conditions

By leaning on Hunter to reject reliance on Williams’s longstanding diagnosis, the opinion confirms that:

Defendants with chronic medical conditions must demonstrate a material post‑sentencing change: either deterioration of the condition or a significant decline in the adequacy of care.
A condition’s mere persistence over time, even if serious, does not ordinarily become “extraordinary and compelling” without some new development.

This sets a high bar for defendants who have lived with complex conditions throughout their incarceration. To qualify, they will need to point to new complications, changed circumstances in prison medical care, or evidence of worsening health.

5. Relationship to Other Remedies (Eighth Amendment or Civil Actions)

Although not addressed explicitly in the opinion, Williams has an implied boundary‑setting effect: it clarifies what compassionate release can and cannot do in the context of prison medical care.

The decision does not foreclose other avenues for addressing inadequate medical treatment, such as:

Eighth Amendment deliberate‑indifference claims under 42 U.S.C. § 1983 (for state inmates) or Bivens-type actions (for certain federal‑rights violations); or
Administrative grievances and internal BOP remedial processes.

Instead, it implicitly distinguishes compassionate release as a remedy of last resort, available only when medical inadequacy rises to an “extraordinary and compelling” level—meaning that the inadequacy places the inmate at a substantial, demonstrable risk of serious harm that, in context, justifies shortening a lawfully imposed sentence.

IV. Complex Concepts Simplified

For clarity, the following key legal and medical concepts appear in the opinion:

1. Compassionate Release (18 U.S.C. § 3582(c)(1)(A))

This statute allows a court to reduce a prisoner’s sentence before it is fully served if:

There are extraordinary and compelling reasons to do so;
The reduction is consistent with Sentencing Commission policy (U.S.S.G. § 1B1.13); and
The reduction is appropriate in light of the usual sentencing factors (e.g., seriousness of the crime, history and characteristics of the defendant, need to protect the public).

It is not a general mechanism to revisit sentencing; it is reserved for unusual, serious circumstances.

2. “Extraordinary and Compelling Reasons”

Congress did not define this phrase in the statute. Instead, it directed the Sentencing Commission to define it. For medical cases, the Commission now says that such reasons exist if:

The prisoner has a medical condition that needs long‑term or specialized care;
That care is not being provided in prison; and
Without that care, the prisoner faces a serious risk of health deterioration or death.

3. U.S.S.G. § 1B1.13(b)(1)(C)

This is the specific guideline applied in Williams. It deals with situations where:

The prisoner’s medical treatment in prison is inadequate, and
The inadequacy itself places the prisoner at serious risk.

It does not say that the mere existence of a serious illness, by itself, automatically qualifies the prisoner for compassionate release.

4. BOP “Care Level 3” Classification

The BOP classifies inmates by medical “care levels.” A “Care Level 3” designation means:

The inmate has a complex condition;
He or she needs frequent clinical contacts; and
Regular monitoring and treatment are required to prevent hospitalizations or serious complications.

In Williams, this classification confirms the seriousness and complexity of his condition but does not by itself prove that he is not receiving adequate care.

5. Warfarin, Thrombophilia, and Deep Vein Thrombosis

Thrombophilia: A condition in which a person’s blood has an increased tendency to form clots.
Deep Vein Thrombosis (DVT): A blood clot in a deep vein, often in the legs. If the clot travels to the lungs, it can cause a pulmonary embolism, which can be fatal.
Warfarin: A blood thinner used to reduce the risk of clots. It requires periodic blood tests to ensure clotting times are within a safe and effective range.

In this case, the question was whether the prison’s management of warfarin and related testing was so poor that it placed Williams at serious risk of health deterioration or death.

6. Standards of Appellate Review

Abuse of discretion: The appellate court defers to the district court’s judgment unless it was unreasonable, arbitrary, or based on a legal error.
Clear error: A very deferential standard. The appellate court will uphold the district court’s factual findings unless it is firmly convinced a mistake has been made. It is not enough that the appellate court might have weighed the evidence differently; the lower court’s view must be plainly wrong.
De novo review: No deference. The appellate court decides legal questions as if reviewing them for the first time.

In Williams, the key standard is clear error—the lens through which the appellate court evaluates the district court’s assessment of the adequacy of medical care and the existence of risk.

V. Conclusion

United States v. Williams is a focused but significant addition to the Sixth Circuit’s compassionate‑release jurisprudence. It:

Applies the revised Sentencing Commission policy statement at U.S.S.G. § 1B1.13(b)(1)(C) to a claim of inadequate prison medical care;
Clarifies that to establish “extraordinary and compelling” medical circumstances, a defendant must show more than a serious diagnosis—he must show that necessary long‑term or specialized care is not being provided and that this shortfall places him at a serious risk of health deterioration or death;
Reaffirms that unchanged conditions known at sentencing cannot alone support compassionate release, per Hunter;
Emphasizes the critical role of individualized, expert‑supported medical evidence and prison medical records in evaluating such claims; and
Underscores the deference appellate courts will give to district courts’ factfinding under the clear‑error standard.

For future litigants and courts, Williams sets a clear evidentiary benchmark: allegations of substandard care, generalized medical advice, and systemic critiques of prison health services must be translated into concrete, individualized proof that the defendant is not receiving necessary care and that this deficiency places him at substantial risk of serious harm. Only then will medical‑care‑based compassionate release meet the “extraordinary and compelling” threshold required by § 3582(c)(1)(A) and § 1B1.13(b)(1)(C).