SAMARITAN PROJECTS NEWSLETTER

09.28.26

CR/RIS Medical: United States v. McDuffy, 2026 U.S. Dist. LEXIS 217199 (Dist. Nevada Sept. 24, 2026)

Who: Defendant Van McDuffy, a federal inmate (now 78) serving two consecutive life sentences for bank robbery with a dangerous weapon resulting in death and for using a firearm during a crime of violence causing death.

What happened: McDuffy, convicted in 2016 for a 2016 bank robbery in which he shot and killed a customer, sought compassionate release under 18 U.S.C. § 3582(c)(1)(A) based on terminal metastatic cancer, stage 5 chronic kidney disease, hypertension, advanced age, and limited mobility. The court found he exhausted administrative remedies, agreed his medical condition constituted extraordinary and compelling reasons, concluded the § 3553(a) factors did not weigh against release, and reduced his sentence to time served with lifetime supervised release.

Why it matters / relevance: The decision applies compassionate-release law to grant relief despite a violent conviction, illustrating how terminal illness, advanced age, and medical vulnerability can outweigh punishment and public-safety concerns under § 3582(c) and § 3553(a); it also signals that courts may release severely ill inmates when adequate supervision and medical placement are feasible.

CR/RIS sole caregiver United States v. Fernandez 2026 U.S. Dist. LEXIS 216128 S.D.N.Y. Sept. 23, 2026)

Who: Defendant Joe Fernandez, convicted in 2013 of conspiracy to use interstate commerce facilities in the commission of murder-for-hire (Count One) and using a firearm in furtherance of a crime of violence resulting in death (Count Two); originally sentenced in 2014 to two consecutive life terms (one life term later vacated).

What happened: Fernandez filed a second compassionate-release motion under 18 U.S.C. § 3582(c)(1)(A)(i) (filed Jan. 9, 2025). After briefing following a 2026 Supreme Court decision limiting grounds for compassionate release, the district court found that a combination of (1) Fernandez’s need to serve as sole caregiver for his incapacitated wife and minor child, (2) his demonstrable rehabilitation (including 18 months free in the community with steady work and volunteer service), and (3) harsh and violent conditions of confinement (including a severe assault in April 2026) constituted extraordinary and compelling reasons. The court considered the § 3553(a) factors and reduced his sentence to time served, imposing five years of supervised release; release effective October 7, 2026.

Why it matters / relevance: The opinion shows courts can grant compassionate release based on a cumulative set of personal circumstances (caregiving need, rehabilitation, and severe prison conditions) even where challenges to conviction are unavailable as grounds; it clarifies how family caregiving and post-release conduct can weigh with § 3553(a) factors to justify reducing a long sentence.

CR/RIS Medical: United States v. Isaac, 2026 U.S. Dist. LEXIS 216743 (S.D.Ill. September 23, 2026)

Who: Defendant William Isaac, federally convicted and sentenced in 2019 to 15 years for two counts of distributing child pornography and one count of receipt; currently in custody and suffering severe medical conditions including end-stage renal disease (ESRD), heart disease, diabetes, and prior stroke.

What happened: Isaac filed a compassionate-release motion under 18 U.S.C. § 3582(c)(1)(A) asking to reduce his sentence to time served because of ESRD and related medical risks (and because remaining in custody likely prevents timely transplant). The court found Isaac satisfied exhaustion, concluded ESRD (and the transplant-timing catch‑22) and his other circumstances qualify as extraordinary and compelling reasons, determined the § 3553(a) factors do not oppose release (noting his prison record, low recidivism risk, support plan, and that he has served roughly half his sentence), and granted compassionate release subject to a short stay for probation to vet release/housing conditions.

Why it matters / relevance: The decision illustrates that end-stage organ disease (ESRD) and medical-treatment timing issues can constitute extraordinary and compelling reasons for compassionate release, and that courts may reduce significant sentences when medical necessity, lack of danger to the community, and adequate post-release supervision together make continued imprisonment effectively a death sentence or otherwise unjust.

CR/RIS Medical: United States v. Lee, 2026 U.S. Dist. LEXIS 217875 (C.D.Cali Sept. 18, 2026)

Who: Defendant Mitchell Vaughn Lee, serving a 60-month federal sentence.

What happened: Lee filed a compassionate-release motion under 18 U.S.C. § 3582(c)(1)(A); he exhausted administrative remedies and the parties agreed (Government non‑opposition) that he has a terminal illness. The court found extraordinary and compelling reasons, considered the § 3553(a) factors, reduced his sentence to time served, and denied supervised release given his deteriorating condition.

Why it matters / relevance: Confirms that terminal illness can justify compassionate release even absent opposing party resistance; shows courts may rescind supervised‑release requirements when a defendant’s medical condition makes further supervision impractical; and illustrates streamlined resolution when the government does not oppose.

CR/RIS: home confinement. United States v. Leitao, 2026 U.S. App. LEXIS 28732 (4th Cir.Sept. 17, 2026)

Who: Louie Fernando Leitao, convicted of coercion and enticement of minors (18 U.S.C. § 2422(b)), sentenced to 120 months’ imprisonment followed by life supervised release.

What happened: Leitao moved under 18 U.S.C. § 3582(c)(1)(A) to reduce his sentence to time served, primarily citing his wife's incapacitating mental illness and his own age/medical conditions. While the motion was pending the BOP transferred Leitao to home confinement. The district court denied the motion as moot. The Fourth Circuit (accepting the government’s unopposed remand request) vacated that ruling and remanded, holding the motion was not necessarily moot because Leitao remained in BOP custody and the district court could still grant effectual relief (reduce the prison term to time served and trigger supervised release).

Why it matters / relevance: Confirms that transfer to home confinement does not automatically moot a compassionate‑release motion; courts retain authority to grant a sentence reduction to time served (which has different legal effects, including starting supervised release). The decision aligns the Fourth Circuit with other circuits recognizing that home confinement provides partial—but not necessarily complete—relief under § 3582(c)(1)(A).

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