When Rehabilitation Alone Is Not “Extraordinary and Compelling”: Sixth Circuit’s Clarification of Compassionate Release and § 3582 Sentence Reductions

Introduction

United States v. Dameus Parks, Jr., No. 24-5566 (6th Cir. Apr. 9, 2025), clarifies two distinct but related areas of federal sentencing law: (1) the scope of “extraordinary and compelling reasons” under 18 U.S.C. § 3582(c)(1)(A) for compassionate release, and (2) the proper exercise of discretion under 18 U.S.C. § 3582(c)(2) for sentence reductions when the Sentencing Guidelines are amended.

In this appeal, the Sixth Circuit affirmed both the district court’s denial of Mr. Parks’s compassionate release motion and the extent of the twelve-month reduction his sentence received under the amended Guidelines. Parks, a convicted felon in possession of a firearm who also pled guilty to conspiring to distribute marijuana, had sought release based on exemplary rehabilitation efforts. He further challenged the district court’s decision to limit his sentence reduction under Amendment 821 to the Sentencing Guidelines.

Summary of the Judgment

The Sixth Circuit unanimously affirmed. First, it held that rehabilitation—even combined with community support and other post-sentencing developments—does not, by itself, constitute an “extraordinary and compelling” reason for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The panel emphasized that Congress and the Sentencing Commission have excluded rehabilitation as a standalone ground, although it may be considered alongside other genuinely extraordinary factors.

Second, the court upheld the district court’s twelve-month reduction under § 3582(c)(2) and Amendment 821, which removed certain “status” points from Parks’s criminal history score. It found no abuse of discretion in the district court’s weighing of the § 3553(a) factors or in its consideration of the benefits Parks obtained by pleading guilty.

Analysis

Precedents Cited

United States v. Ruffin, 978 F.3d 1000 (6th Cir. 2020) – Standards of review for compassionate release motions (abuse of discretion).
United States v. Elias, 984 F.3d 516 (6th Cir. 2021) – “If any one” of the statutory prerequisites for § 3582(c)(1)(A) relief is missing, the court need not address the others.
U.S.S.G. § 1B1.13(b)–(d) (Policy Statement) – Defines “extraordinary and compelling reasons” and confirms that rehabilitation alone is excluded but may supplement other reasons.
United States v. Hunter, 12 F.4th 555 (6th Cir. 2021) – Post-sentencing developments, not factors considered at original sentencing, form the core of “extraordinary and compelling” analysis.
United States v. Dillon, 560 U.S. 817 (2010) – Two-step framework for § 3582(c)(2) reductions: (1) eligibility under § 1B1.10, (2) discretionary § 3553(a) analysis.
Hughes v. United States, 584 U.S. 675 (2018) – Even within a Rule 11(c)(1)(C) (“Type C”) plea agreement, the Guidelines range remains a “basis” for sentencing and qualifies under § 3582(c)(2).

Legal Reasoning

1. Compassionate Release (§ 3582(c)(1)(A)) Section 3582(c)(1)(A) permits sentence modifications only upon (a) a finding of “extraordinary and compelling reasons,” (b) consistency with Sentencing Commission policy statements, and (c) consideration of the § 3553(a) factors. Congress explicitly disallowed rehabilitation alone as an “extraordinary and compelling” ground (28 U.S.C. § 994(t)), a directive mirrored in U.S.S.G. § 1B1.13.

Parks’s arguments—based primarily on post-sentencing rehabilitation, community support, and personal growth—failed to satisfy the statutory requirement. The Sixth Circuit stressed that “rehabilitation” is distinct from other humanitarian grounds (serious illness, advanced age, family circumstances, etc.) and that prior sentencing considerations cannot be relitigated as extraordinary circumstances.

2. Section 3582(c)(2) and Amendment 821 Amendment 821 retroactively removed “status points” for offenders under criminal justice supervision at the time of the offense. Parks’s Guidelines range dropped from 46–57 months to 41–51 months. Although he received a 108-month sentence under a Rule 11(c)(1)(C) plea deal, the Supreme Court in Hughes clarified that such a sentence remains “based on” the Guidelines range, rendering Parks eligible under § 3582(c)(2).

At the second step, the district court applied the § 3553(a) factors—considering offense seriousness, Parks’s history, public safety, respect for the law, and sentencing disparity concerns—and proportionally reduced his term by 12 months. On appeal, the Sixth Circuit declined to reweigh these discretionary judgments, noting the highly deferential standard applied to sentencing courts’ balancing of § 3553(a) factors.

Impact

For Future Compassionate Release Motions: This decision cements the principle that exemplary rehabilitation—no matter how extensive—cannot by itself trigger compassionate release under § 3582(c)(1)(A). Defendants and district courts must identify other extraordinary and compelling circumstances (e.g., terminal illness, advanced age, catastrophic family events) beyond mere rehabilitation efforts.

For Sentence Reductions Under § 3582(c)(2): The Sixth Circuit’s application of Amendment 821 reaffirms that retroactive guideline reductions benefit even those who pled under Rule 11(c)(1)(C). Moreover, sentencing courts retain broad discretion in weighing § 3553(a) factors and may consider the benefits a defendant received through plea bargaining.

Complex Concepts Simplified

Extraordinary and Compelling Reasons: A narrow set of reasons—like severe medical conditions or family crises—explicitly excluding rehabilitation alone.
Section 3582(c)(1)(A) vs. 3582(c)(2): (c)(1)(A) governs compassionate release for humanitarian reasons; (c)(2) allows sentence reductions when the Guidelines change after sentencing.
Rule 11(c)(1)(C) Plea Agreement (“Type C”): A binding agreement in which the parties recommend a specific sentence; even so, the Guidelines range remains a reference point and may be adjusted retroactively.
§ 3553(a) Factors: Statutory considerations for sentencing: offense seriousness, history and characteristics of the defendant, public safety, deterrence, and consistency.

Conclusion

United States v. Parks establishes a clear boundary: while lawful and laudable, post-sentencing rehabilitation cannot by itself constitute an “extraordinary and compelling” reason for compassionate release. Judges must look beyond rehabilitation to other statutory grounds. Simultaneously, the case reaffirms that retroactive guideline amendments benefit all eligible defendants—including those who pled under a Rule 11(c)(1)(C) agreement—and that district courts have wide latitude in applying § 3553(a) factors when crafting sentence reductions.

This ruling will guide defense counsel in framing compassionate release petitions and will inform district courts’ discretionary sentencing decisions under §§ 3582(c)(1)(A) and (c)(2), enhancing clarity and consistency in this evolving area of federal sentencing law.