SAMARITAN NEWSLETTER – 03.13. 2026

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SUPREME COURT - Villarreal v. Texas, 2026 U.S. LEXIS 1103, No. 24-577 (Sup. Ct. Feb. 25, 2026). During his murder trial, the defendant chose to testify in his own defense, claiming self-defense in the fatal stabbing. Partway through his testimony, the trial was interrupted by a 24-hour overnight recess. Before the break, the trial judge instructed defendant’s attorneys not to “manage” or shape his ongoing testimony during the recess but clarified the defendant was not barred from speaking with his lawyers about other matters, such as sentencing or trial strategy. After the recess, defendant resumed testifying and was later convicted of murder. The Texas Court of Criminal Appeals reviewed the trial judge’s conferral order. The appellate court found the order was constitutionally permissible because it only restricted discussions specifically about managing the defendant’s ongoing testimony, not all attorney-client consultations. The appellate court emphasized the order did not prevent the defendant from consulting his attorneys on other protected matters, such as plea negotiations or trial strategy, and was therefore a proper exercise of the trial court’s discretion. The Supreme Court addressed whether a qualified order limiting discussion of a defendant’s ongoing testimony during a mid-testimony overnight recess violates the Sixth Amendment right to counsel. The Supreme Court held such a qualified order is constitutional, so long as it prohibits only discussion of testimony for its own sake and does not prevent consultation on other protected topics, including trial strategy, plea discussions, or evidentiary issues. The Court distinguished this qualified order from a total ban on attorney-client discussions and affirmed the order properly balanced the defendant’s right to counsel against the integrity of unaltered trial testimony. The judgment of the Texas Court of Criminal Appeals was affirmed.

CR.RIS/MEDICAL. The Western District of Washington granted a CR.RIS motion in United States v. Titus Peterson, 2026 U.S. Dist. LEXIS 36660 (W.D. Wash. Feb. 23, 2026). Peterson established the BOP has not provided the specialized care necessary to manage his type I diabetes, and the 18 USC 3553(a) sentencing factors support the requested reduction, the court granted his motion. On June 3, 2013, Peterson was sentenced to 240 months for drug and firearm offenses. A medical expert, Dr. David Hellerstein, reviewed Peterson's records and determined the BOP's care of Peterson has been "atrocious" and violated the standard of care. Courts are now "bound by" 1B1.13 in deciding all compassionate release motions under 3582(c)(1)(A). Peterson pointed to Dr. Hellerstein's conclusion the BOP failed to provide the specialized standard of care in multiple ways, including by failing to adequately respond, evaluate, and monitor Peterson when his blood sugar was dangerously high and failing to modify Peterson's insulin regimen to meet the current standard of care. The court concluded Peterson met his burden of establishing the BOP is not providing the specialized medical care necessary to treat his diabetes and as a result he has suffered serious harm. Under 1B1.13, Peterson established an extraordinary and compelling reason warranting relief. Sentence reduced to time served.

CR.RIS/REHABILITATION/DISPARITY. The District of Maryland granted a CR.RIS motion in United States v. Eduado Countess, 2026 U.S. Dist. LEXIS 34621 (D. Md. Feb. 20, 2026). Countess is serving multiple life sentences for murder. Countess's co-defendants accepted plea bargains and were sentenced to significantly shorter terms of imprisonment that have now run their course. Countess was indicted on six charges related to a murder for hire conspiracy. He raised several grounds in support of his claim that he has established extraordinary and compelling circumstances for compassionate release including "the disparity between [his] sentence and the sentence imposed on his co-conspirators," "the disparity between [his] sentence and the sentence he would likely receive if he were sentenced today," and his "relative youthful age at the time of his criminal acts." The difficult upbringing Countess endured and his relatively young age (25) at the time of the murder support a finding of extraordinary and compelling reasons supporting a reduced sentence. Countess has taken significant steps to rehabilitate himself while in custody. He received the highest average score on the GED test at USP Canaan and has become a solid UNICOR contributor and certified operator of heavy machinery. He has completed other courses and has maintained a relatively clean disciplinary record. Sentence reduced to 35-years imprisonment.

CR.RIS/MEDICAL/USSG 1B1.13(b)(2). The Southern District of New York granted a CR.RIS motion in United States v. Frank Castillo, 2026 U.S. Dist. LEXIS 31805, 2026 WL 444695 (S.D. N.Y. Feb. 17, 2026). A jury found Castillo guilty of (1) possession of a firearm following a felony conviction; (2) conspiracy to commit armed bank robberies; (3) three counts of armed bank robbery; and (4) three counts of using and carrying a firearm during a crime of violence. The Court sentenced Castillo to life which sentence was then mandatory. Castillo contended he is "experiencing a serious deterioration in physical or mental health because of the aging process[,]" which constitutes an extraordinary and compelling reason for release. USSG 1B1.13(b)(2). Defendant suffers from a combination of several serious medical conditions, including having had a heart attack, chronic kidney disease, prostate disorder, prediabetes, hypertension, hyperlipidemia, and problems with his vision. He properly argued, under 1B1.13(b)(2), the Court is not concerned with whether the BOP is appropriately managing Castillo's medical conditions. Instead, the Court looks at whether Castillo has articulated "a trend of seriously deteriorating health related to the aging process." Sentence reduced to time served.

CR.RIS/FAMILY CIRCUMSTANCES. The Middle District of Tennessee granted a CR.RIS motion in United States v. Terry White, 2026 U.S. Dist. LEXIS 34626, 2026 WL 446650 (M.D. Tenn. Feb. 17, 2026). White's eight-year-old son was diagnosed with a cancerous brain tumor in October 2025 that cannot be cured, and his son's condition continues to deteriorate. Without treatment, children with White's Son's condition generally have only sixth months to live, and with treatment, survival time can only be extended nine to eleven months. The Government agreed that compassionate release is warranted because the "terminal illness" of White's "young son" is an "extraordinary and compelling reason for the relief." Sentence reduced to time served.

CR.RIS/DISPARITY/REHABILITATION/STACKING. The Eastern District of Virginia granted a CR.RIS motion in United States v. Spencer Coley, 2026 U.S. Dist. LEXIS 30692 (E.D. Va. Feb. 13, 2026). Defendant was charged with Interference with Commerce by Robbery, and Brandishing a Firearm in Furtherance of Crime of Violence. He was sentenced of 324 months. He presented three arguments in support of the request for compassionate release: (1) rehabilitation; (2) age and mental health at the time of the offense; and (3) the disparity of his sentence, given the recent changes to 18 USC 924(c). Coley argued he has "focused on education, self-improvement, and becoming a changed man." Coley asserted he now has a proactive attitude about his mental health and takes his medication, and that his job and the classes he has taken combined with his lack of infractions since 2019 reflect he has taken control of his mental health. While incarcerated, Coley earned his GED, has largely been disciplinary infraction free for years, and is in the Challenge Program, all of which reflect successful self-improvement efforts. The Government listed 30 infractions Coley has received. There is a disparity between what Coley received (324 months) for the three counts of conviction and the guideline range today for those three counts is significant: 324 months versus 151-174 months. The combination of the very significant sentencing disparity, Coley's youth at the time of his crimes, and his struggles with mental health constituted extraordinary and compelling reasons to reduce Coley's sentence. Sentence reduced to 174 months imprisonment.

CR.RIS/MEDICAL/REHABILITATION. The District of the Virgin Islands, Division of St. Croix granted a CR.RIS motion in United States v. Lestroy Bright, 2026 U.S. Dist. LEXIS 30237, 2026 WL 412525 (D. V.I. Feb. 13, 2026). Defendant was convicted by jury of three counts of robbery affecting interstate commerce; three counts of use of a firearm during a crime of violence; and certain local offenses and was sentenced to 675 months In view of the defendant's serious medical condition, the Court reduced his period of incarceration to time served. Defendant is "paralyzed on the entire left side of his body as a result [of] a stroke that further caused him to use a walker, cane and wheelchair" and he is in serious risk of contracting COVID-19 because he suffers from "conditions such as high blood pressure and obesity." Defendant also made arguments pursuant to USSG 1B1.13(b)(1)(C) and 1B1.13(b)(5). However, because the Court granted the requested relief under 1B1.13(b)(1)(B), the Court did not reach these alternative arguments. Sentence reduced to time served.

CR.RIS/MEDICAL. The Eastern District of Michigan granted a CR.RIS in United States v. Allen Earl, 2026 U.S. Dist. LEXIS 31018, 2026 WL 381178 (E.D. Mich. Feb. 5, 2026). Earl moved the Court to grant compassionate release due to his serious health issues, including Stage III renal cell carcinoma. Earl pled guilty to one count of possession with intent to distribute over 40 grams of fentanyl and was sentenced to 60 months. At the time of sentencing, Earl had been diagnosed with several health conditions, including Atrial Fibrillation/Hypothyroidism, Chronic Congestive Heart Failure, Chronic Kidney Disease (Stage III), Hypertension, Hyperlipidemia (High Cholesterol), Anemia, Glaucoma, Gastroesophageal Reflux Disease, Obstructive Sleep Apnea, Bulging/Degenerative Disc Disorder, and Osteoarthritis in both knees. Earl contended his health has continued to deteriorate including he has developed growing renal masses on both kidneys, and he is now a "Care Level 4" prisoner, the highest level of care in the BOP. Earl has shown that, despite being categorized as a Care Level 4 inmate, the medical care he is receiving from the BOP is inadequate to fully address his serious medical issues, and in particular his diagnosis with Stage III renal cell carcinoma, because of the BOP's striking delays and lack of follow up treatment. Sentence reduced to time served.