United States of America v. John M. Griffin

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted June 4, 2025*
Decided June 12, 2025
Before
MICHAEL B. BRENNAN, Circuit Judge
MICHAEL Y. SCUDDER, Circuit Judge
THOMAS L. KIRSCH II, Circuit Judge
No. 24-1970
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
JOHN M. GRIFFIN,
Defendant-Appellant.
Appeal from the United States District
Court for the Southern District of
Indiana, Indianapolis Division.
No. 1:19-cr-00208-JRS-TAB-2
James R. Sweeney II,
Judge.
O R D E R
John Griffin appeals the denial of his motion for compassionate release under
18 U.S.C. § 3582(c)(1)(A)(i). The district court concluded that Griffin failed to establish
an extraordinary and compelling reason for early release, and alternatively, that the
* We have agreed to decide the case without oral argument the briefs 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NONPRECEDENTIAL DISPOSITION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. 24-1970 Page 2
18 U.S.C. § 3553(a) factors weighed against granting his motion. Because the court did
not abuse its discretion, we affirm.
Background
In 2021, Griffin pleaded guilty to one count of conspiracy to possess (with intent
to distribute) and to distribute “actual” methamphetamine. 21 U.S.C. §§ 841(a)(1) and
846. At sentencing, the district court found that Griffin conspired to distribute 2.24
kilograms of “actual” methamphetamine, a quantity that corresponded to a base offense
level of 36. See U.S.S.G. § 2D1.1(a)(5), (c)(2). The district court then sentenced him to
168 months’ imprisonment followed by 5 years of supervised release.
Less than three years later, in early 2024, Griffin sought compassionate release
under 18 U.S.C. § 3582(c)(1)(A)(i). He argued for early release, citing a trend among
district courts to reject the Guidelines’ tenfold increase for possession of “ice” or
“actual” methamphetamine (compared to less potent mixtures). Furthermore, he
asserted that he had made significant rehabilitative progress.
The district court denied Griffin’s motion, concluding that he failed to
demonstrate an extraordinary and compelling reason for relief. The court dismissed his
sentencing-disparity argument for three reasons. First, any challenge to the original
sentence needed to be made on direct appeal or collaterally through 28 U.S.C. § 2255,
not by way of a compassionate-release motion. Second, U.S. v. Thacker prohibits early
release based on nonretroactive legal changes, establishing that neither statutory
changes nor new judicial decisions constitute an extraordinary and compelling reason.
See 4 F.4th 569, 575 (7th Cir. 2021). Third, Griffin was ineligible for early release under
the 2023 Amendments to the Sentencing Guidelines regarding unusually long sentences
because he had not yet served ten years.† The court then rejected Griffin’s rehabilitation
argument, stating that rehabilitation alone was not a sufficient reason for compassionate
release. Alternatively, the court found that even if an extraordinary and compelling
reason existed, the sentencing factors under 18 U.S.C. § 3553(a) did not favor early
release, citing the seriousness of Griffin’s crime and his two prior felony convictions.
† The district court issued its decision before we concluded that the Sentencing
Commission exceeded its authority in promulgating the 2023 Amendments to the
Sentencing Guidelines (specifically U.S.S.G. § 1B1.13(b)(6)). See United States v. Black,
131 F.4th 542, 543 (7th Cir. 2025).

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No. 24-1970 Page 3
Analysis
Griffin appeals the denial of his compassionate-release motion, a ruling that we
review for an abuse of discretion. United States v. Black, 131 F.4th 542, 545 (7th Cir. 2025).
Since the parties completed briefing, we decided Black, which addressed the fate of
Thacker and its progeny after the Sentencing Commission regained its quorum and
issued U.S.S.G. § 1B1.13(b)(6). Although Black’s holding was specific to 18 U.S.C.
§ 924(c), it reiterated that Thacker “remains binding law, and the Commission’s attempt
to say otherwise [by promulgating U.S.S.G. § 1B1.13(b)(6)] exceeds its statutory
authority.” Id. at 543. Black thus reinforces the district court’s intuition that
nonretroactive changes in law may not be considered extraordinary and compelling
reasons for relief. Id.
Griffin argues that the district court erred by not evaluating his arguments
cumulatively. He highlights the language of § 1B1.13(d), which allows for the
consideration of rehabilitation “in combination with other circumstances.” One such
circumstance, he posits, is the evolving judicial skepticism toward disparate sentences
for convictions involving “actual” or “ice” methamphetamine Relatedly, he equates this
judicial trend with a “change in the law” under § 1B1.13(c).
A combination of arguments can constitute an extraordinary and compelling
reason, United States v. Vaughn, 62 F.4th 1071, 1073 (7th Cir. 2023), but here, the district
court appropriately exercised its discretion in ruling that Griffin’s arguments did not tip
the balance. The court rightly refused to consider Griffin’s sentencing-disparity
argument, see Black, 131 F.4th at 546, and rehabilitation—without more—cannot
constitute an extraordinary and compelling reason for release. See United States v.
Peoples, 41 F.4th 837, 841 (7th Cir. 2022); U.S.S.G. § 1B1.13(d).
As to the assessment of the § 3553(a) factors, Griffin also asserts the district court
ignored considerations, such as his rehabilitation and the changing legal landscape of
methamphetamine. But this argument is beside the point, given the court’s correct
determination that he did not first establish an extraordinary and compelling reason for
compassionate release. See United States v. Williams, 65 F.4th 343, 349 (7th Cir. 2023).
Regardless, when considering the § 3553(a) factors, a district court need identify only
“one good reason” to deny relief, United States v. Rucker, 27 F.4th 560, 563 (7th Cir. 2022),
and the court acted well within its discretion to find that Griffin’s serious crime and
criminal history weighed against early release.
AFFIRMED

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