SAMARITAN NEWSLETTER 07.15.26

SAMARITAN PROJECTS LLC

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The SAMARITAN-PROJECT prepares post-conviction and compassionate release motions under the direction of Attorney Tom Norrid. The Project retrieves documents at reasonable prices. The Project newsletter reports every winning published district court and court of appeals case for the week in review.

CR/RIS Elderly parent: United States v. Schiff, 2026 U.S. Dist. LEXIS 152937 (ND Ill) July 10, 2026, Decided; July 10, 2026, Filed Case No. 19-CR-474-1

In the case of United States v. Schiff, the defendant, Schiff, presents a compelling argument centered around the health crisis faced by his elderly mother, who has been diagnosed with Stage 3B colon cancer. This diagnosis is critical as it signifies a serious progression of the disease, which not only poses immediate health risks but also requires extensive and ongoing medical attention and caregiving support. Schiff contends that his mother’s condition necessitates substantial caregiving, which, unfortunately, is beyond the capacity of any family member to provide at this time. The emotional and physical toll of such a diagnosis is immense, and it is compounded by the fact that the family is unable to rally around her to provide the necessary support during this challenging period.

In a significant development, the Government has concurred with Schiff's assertion that his mother's medical condition constitutes an extraordinary and compelling reason for a potential reduction in his sentence under the provisions of § 3582(c)(1)(A). This section of the law allows for compassionate release under certain circumstances, particularly when the health of a defendant's family member is in jeopardy, thereby impacting the defendant's circumstances and their ability to serve their sentence effectively.

To bolster his case, Schiff submitted two letters from medical professionals that outline the need for assistance with pain management for his mother. However, it is noteworthy that these letters fall short of providing a comprehensive overview of her medical situation. They do not delve into critical aspects such as her overall incapacitation, the specifics of her cancer diagnosis, the various treatments she has undergone, or the necessary post-operative care that she might require. Instead, the letters merely indicate that she requires help with homemaking tasks, which, while important, does not fully encapsulate the gravity of her condition or the extent of care she truly needs.

When evaluating Schiff’s motion for compassionate release, it becomes apparent that while his case may not be as robust as others that have been presented in similar circumstances, the Government has nonetheless acknowledged the severity of his mother's health condition as a valid reason for considering a reduction of his sentence. This acknowledgment reflects a broader understanding of the implications that serious familial health issues can have on individuals who are incarcerated.

Ultimately, in light of the considerations surrounding his mother's dire health situation and the recognition of the extraordinary circumstances presented, Schiff's motion for compassionate release has been granted. This decision underscores the legal system's capacity to adapt and respond to humanitarian concerns, particularly in cases involving vulnerable family members who are in critical need of support and care.

CR/RIS Care of parent United States v. Malik First Born Allah Farrad, 2026 U.S. Dist. LEXIS 145865   Tennessee (ED TN)  July 1, 2026

The defendant requests relief under § 1B1.13(b)(3)(C) and/or § 1B1.13(b)(5) [Sealed Doc. 118]. Section 1B1.13(b)(3)(C) allows for compassionate release due to certain family circumstances, specifically, "[t]he incapacitation of the defendant's parent when the defendant would be the only available caregiver for the parent." U.S. Sent'g Guidelines Manual § 1B1.13(b)(3)(C) (U.S. Sent'g Comm'n 2025). Section 1B1.13(b)(5) indicates that extraordinary and compelling reasons may be present when a "defendant presents any other circumstance or combination of circumstances that, when considered by themselves or together with any of the reasons described in paragraphs (1) through (4), are similar in gravity to those described in paragraphs (1) through (4)."1Link to the text of the note U.S. Sent'g Guidelines Manual § 1B1.13(b)(5) (U.S. Sent'g Comm'n 2025).

The defendant seeks compassionate release specifically to care for his 67-year-old mother, who has a complex history of serious health issues.

His mother suffers from a range of medical conditions, including a history of strokes, seizure disorder, a history of brain aneurysms, chronic obstructive pulmonary disorder, cirrhosis of the liver, dementia, vision loss, hearing loss, and hyponatremia [Id.]. She is also clinically underweight [Id. at 6]. The defendant particularly emphasizes that his mother's current living situation is "exceptionally dire."

After considering the relevant § 3553(a) factors and the evidence presented, the Court concludes that these factors justify the defendant's compassionate release. The requirement for exhaustion has been met, an extraordinary and compelling reason exists, and the applicable § 3553(a) factors support compassionate release; thus, the Court deems compassionate release appropriate. The defendant's motion for compassionate release [Sealed Doc. 118] is hereby GRANTED.

CR/RIS Medical United States v. Larson, 2026 U.S. Dist. LEXIS 148954 (E.D.Wis) July 1, 2026 This relief is deemed appropriate and necessary due to the extraordinary and compelling reason that the Bureau of Prisons (BOP) has been unable or unwilling to provide the specialized medical care needed for Mr. Larson's worsening and serious medical condition of lymphedema with open wounds on his upper legs." Dkt. No. 31 at 1. "Without the necessary treatment for nearly eight months, severe swelling and open wounds have developed on Mr. Larson's upper legs, where these issues were not present before his incarceration."

Although the Government's suggestion that Larson's physical condition may have deteriorated partly due to his own actions is not entirely without merit, the court is convinced that Larson's current condition qualifies as an extraordinary and compelling reason to adjust his sentence. The risk of infection and the potential need for amputation or even worse outcomes for this 73-year-old man, despite the BOP's efforts to address his medical needs, justifies the relief he seeks. Reducing his sentence to time served will enable him to receive the medical care he was receiving before his incarceration and hopefully prevent further health risks. In conclusion, the court determines that the criteria of § 3582(c)(1)(A) are satisfied. Larson's motion to reduce his sentence to time served is granted.

CR/RIS Mothers health, rehabilitation United States v. Risher, 2026 U.S. Dist. LEXIS 143892 (E.D.N.Y.) June 29, 2026

The case of Risher presents a compelling narrative that highlights several extraordinary and compelling reasons that fulfill the gatekeeping requirement for sentence modification under the relevant legal frameworks. Specifically, Risher articulates four significant factors that warrant consideration: the deteriorating health of his mother, his own pressing health concerns, the "unnecessarily punitive" conditions under which he is currently incarcerated, and substantial evidence of his rehabilitation throughout his time in custody.

Delving deeper into these factors, it becomes clear that Risher's mother's health is a particularly poignant aspect of his argument. As a full-time caregiver, she requires assistance due to her declining health, which not only affects her quality of life but also places a considerable emotional burden on Risher. The relationship between a mother and son can be profoundly impactful, and the distress caused by her health issues is compounded by the physical separation imposed by Risher's incarceration. This situation creates a compelling case for why he should be granted a sentence reduction, as it would allow him to provide the necessary support and care that his mother desperately needs during this challenging time.

In addition to familial obligations, Risher's own health issues play a critical role in his plea for reconsideration of his sentence. The conditions of his incarceration have reportedly exacerbated these health concerns, leading to a situation that could be characterized as unnecessarily punitive. The legal framework surrounding incarceration emphasizes not only punishment but also rehabilitation and the overall well-being of inmates. Risher's argument suggests that his continued confinement under these harsh conditions serves no constructive purpose and only hinders his path to recovery and reintegration into society.

Among the four factors presented, it is essential to recognize that Risher's exceptional rehabilitation stands out as a cornerstone of his request for a sentence reduction. Evidence of his commitment to personal growth, development of new skills, and positive contributions to the prison community reflect a transformation that aligns with the rehabilitative goals of the criminal justice system. His journey underscores the potential for change and redemption, illustrating that individuals can overcome past mistakes and emerge as responsible, contributing members of society.

When evaluating these factors, it is crucial to consider them through the lens of the First Step Act's gatekeeping requirement as well as the primary 3553(a) factors that guide sentencing decisions. Risher's demonstrated rehabilitation, coupled with the pressing need to support his ailing mother, collectively create a robust justification for granting his request for a reduction of his sentence to time served. This consideration not only acknowledges the realities of his personal circumstances but also reflects a broader understanding of justice that emphasizes compassion, family unity, and the potential for positive change.

CR/RIS Medical conditions United States v. Blank, 2026 U.S. Dist. LEXIS 141869 (M.D.F.) June 26, 2026. In this notable case, the defendant, Blank, has presented a compelling argument regarding his severe and life-threatening medical conditions. Specifically, he is afflicted with chronic renal failure classified as Stage 4, which is a critical stage of kidney disease where the kidneys are severely impaired and unable to perform their essential functions effectively. Additionally, Blank suffers from advanced kidney disease, indicating a progressive deterioration of kidney function that poses significant health risks. Furthermore, he is battling anemia, a condition characterized by a deficiency of red blood cells or hemoglobin in the blood, leading to fatigue and weakness. Compounding his health issues, Blank is also diagnosed with multiple melanoma cancer, a serious and aggressive form of skin cancer that can spread to various parts of the body, further complicating his overall health status. The Warden Recommendation in this case highlights the gravity of Blank's medical conditions and indicates that the Government does not oppose his compassionate release. This is a significant development, as it reflects a consensus on the severity of Blank's health issues. The Government acknowledges that Blank's prior request for compassionate release in 2020 was appropriately denied (Doc. 102), which suggests that at that time, his medical situation may not have reached the level of urgency that it currently exhibits. However, the Government now submits that Blank's medical conditions have significantly worsened since that initial denial, leading to a reassessment of his circumstances. The Government argues that Blank's deteriorating health now constitutes extraordinary and compelling circumstances that warrant his release from incarceration. This acknowledgment underscores the evolving nature of medical evaluations within the criminal justice system, particularly as they relate to the compassionate release provisions. The case emphasizes the importance of considering an inmate's health status, especially in light of severe and life-threatening conditions that could affect their quality of life and overall survival. As the legal proceedings unfold, the implications of Blank's case may set precedents for how similar cases are handled in the future, particularly regarding the intersection of medical needs and incarceration.

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Then there is the heart-breaker:

United States v. Hall , 2026 U.S. App. LEXIS 18561 6th Circuit Court of Appeals

June 25, 2026  In this pivotal case, the Sixth Circuit Court of Appeals addressed a significant issue regarding the interpretation of "extraordinary and compelling" reasons for compassionate release under federal law. The district court's decision to grant Hall's motion for compassionate release was determined to be an abuse of discretion, a ruling that carries substantial implications for future cases involving similar circumstances. The court highlighted that in the earlier case of Hunter, we had already established a precedent that identified an abuse of discretion in a comparable situation, even though at that time, there was no definitive ruling on whether factors such as youth and rehabilitation could be considered as "extraordinary and compelling" under the existing statutory framework. This is reflected in the citation, 12 F.4th at 559.

In the case at hand, the district court not only overlooked the precedent set in Hunter but also acted contrary to the prohibitions established by Bricker. This oversight was critical, as it indicated a failure to adhere to the established legal standards and interpretations that guide the determination of what constitutes extraordinary circumstances warranting compassionate release. The court's decision to interpret Hall's youth and rehabilitation as qualifying factors under the statute was deemed an improper application of the law. Specifically, the court referenced Flowers, 963 F.3d at 497, which underscores the necessity for courts to remain consistent in their interpretations and to follow the established legal precedents when making such determinations.