United States of America v. Jaime Williams

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted May 28, 2024*
Decided May 29, 2024
Before
FRANK H. EASTERBROOK, Circuit Judge
MICHAEL B. BRENNAN, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 24-1325
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
JAIME WILLIAMS,
Defendant-Appellant.
Appeal from the United States District
Court for the Western District of
Wisconsin.
No. 20-cr-145-jdp
James D. Peterson,
Chief Judge.
O R D E R
Jaime Williams, a federal prisoner, appeals the denial of his motion for
compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i). Because the district court
properly ruled that Williams raises no extraordinary and compelling reason for release,
we affirm.
* The appellee is not participating in this appeal. We have agreed to decide the
case without oral argument because the appellant’s brief and record adequately present
the facts and legal arguments, and oral argument would not significantly aid the court.
F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-1325 Page 2
Williams pleaded guilty to possessing a firearm as a felon in violation of
18 U.S.C. § 922(g)(1) and was sentenced in 2021 to 63 months’ imprisonment. In
December 2023, Williams moved for compassionate release under 18 U.S.C.
§ 3582(c)(1)(A)(i) based on (1) the unexpectedly harsh conditions of his confinement
brought about by the COVID-19 pandemic; (2) his participation in every rehabilitation
program offered at the prison; and (3) the effect that the Supreme Court’s decision in
New York State Rifle & Pistol Association v. Bruen, 597 U.S. 1 (2022), would have on his
sentence for violating § 922(g)(1) if he was sentenced today.
Without inviting the government’s response, the district court denied the motion.
First, the court explained that pandemic-related precautions at a prison were not
extraordinary and compelling reasons for release. Second, the court found that
Williams’s rehabilitation efforts, alone, were not an extraordinary and compelling
reason for relief. Last, the court concluded that Williams could not use the
compassionate-release statute as a vehicle to challenge any errors in his underlying
conviction or sentence.
On appeal, Williams renews his challenge regarding his conviction under
§ 922(g)(1), contending that his conviction may have been invalid if he been convicted
today. But as the district court correctly observed, a compassionate-release motion may
not be used as an end run around a direct appeal or collateral attack. See United States v.
Brock, 39 F.4th 462, 466 (7th Cir. 2022). We note that the Sentencing Commission’s 2023
amendments to the Guidelines permits some defendants to seek early release based on
intervening changes in constitutional or criminal law, see U.S.S.G. § 1B1.13(b)(6), but
those amendments limit eligibility to defendants who—unlike Williams—have served
at least ten years of their sentence.
Williams also rehashes his arguments about the pandemic-related conditions at
his prison and his participation in rehabilitation programs. But the district court
appropriately exercised its discretion in rejecting these arguments. Williams gave the
court no reason to suggest that the prison’s response to the COVID-19 pandemic created
an overly harsh sentence. See United States v. Joiner, 988 F.3d 993, 996 (7th Cir. 2021).
Further, his participation in rehabilitation programs is “common rather than
extraordinary,” United States v. Vaughn, 62 F.4th 1071, 1072 (7th Cir. 2023), and
insufficient as an independent basis to warrant early release, see United States v. Peoples,
41 F.4th 837, 841 (7th Cir. 2022).
AFFIRMED

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