5:16-cr-20817•United States of America v. Manderfield
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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION United States of America, Plaintiff, v. Demitrius Elijah-Patrick Manderfield, Defendant. ________________________________/ Case No. 16-20817 Judith E. Levy United States District Judge Mag. Judge Anthony P. Patti OPINION AND ORDER DENYING TIA SUMNER’S REQUEST FOR COMPASSIONATE RELEASE FOR DEMITRIUS MANDERFIELD [94] Before the Court is pro se filer Tia Sumner’s request for compassionate release for Demetrius Manderfield. (ECF No. 94.) In her request, Ms. Sumner states that she is Defendant’s mother. On June 12, 2018, the Court sentenced Defendant to 120 months’ imprisonment after he pleaded guilty to one count of Sex Trafficking of a Minor, in violation of 18 U.S.C. § 1591(a)(1). (ECF No. 74.) Defendant has previously moved for compassionate release and/or a reduction of his Case 5:16-cr-20817-JEL-APP ECF No. 98, PageID.<pageID> Filed 10/22/25 Page 1 of 5
2 sentence. (See ECF Nos. 77, 91.) The Court denied these motions. (ECF Nos. 86, 93.) Under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act of 2018, a motion for compassionate release or modification of a sentence may be filed the Director of the Bureau of Prisons (“BOP”) or by “an imprisoned person . . . after (1) exhausting the BOP’s administrative process; or (2) thirty days after the warden received the compassionate release request—whichever is earlier.” See United States v. Jones, 980 F.3d 1098, 1104–05 (6th Cir. 2020) (citations omitted). In resolving compassionate release motions, courts in the Sixth Circuit apply a three-step inquiry. United States v. Elias, 984 F.3d 516, 518 (6th Cir. 2021). First, “the court must ‘find’ that ‘extraordinary and compelling reasons warrant [a sentence] reduction.’” Id. (alteration in original) (quoting Jones, 980 F.3d at 1101). Second, the Court must “ensure ‘that such a reduction is consistent with applicable policy statements issued by the [United States] Sentencing Commission.’” Id. (quoting Jones, 980 F.3d at 1101). Third, the Court must “consider[] all relevant sentencing factors listed in 18 U.S.C. § 3553(a).” Id. (alteration in original) (quoting Jones, 980 F.3d at 1101). “If each of those Case 5:16-cr-20817-JEL-APP ECF No. 98, PageID.<pageID> Filed 10/22/25 Page 2 of 5
3 requirements are met, the district court ‘may reduce the term of imprisonment,’ but need not do so.” Id. (quoting 18 U.S.C. § 3582(c)(1)(A)). The Court must find that “[e]xtraordinary and compelling reasons exist under any of the following circumstances or a combination thereof”: (1) the medical circumstances of the defendant, (2) the age of the defendant, (3) the family circumstances of the defendant, (4) whether the defendant was a victim of abuse while in custody, and (5) “Other Reasons.” See U.S.S.G. § 1B1.13(b)(1)–(5); see also United States v. Bricker, 135 F.4th 427 (6th Cir. 2025) (holding that U.S.S.G. § 1B1.13(6) is invalid and may not be considered). Under the “Other Reasons” provision, a court may consider “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).” Id. at § 1B1.13(b)(5). First, Ms. Sumner’s motion is improperly filed. As a self- represented person, Ms. Sumner cannot file motions on behalf of her son. Zanecki v. Health All. Plan of Detroit, 576 F. App’x 594, 595 (6th Cir. Case 5:16-cr-20817-JEL-APP ECF No. 98, PageID.<pageID> Filed 10/22/25 Page 3 of 5
4 2014). Further, 18 U.S.C. § 3582(c)(1)(A) specifies that a motion for compassionate release or modification of a sentence may be filed by either Defendant or the Director of the BOP. Ms. Sumner is neither Defendant himself nor the Director. As such, the Court cannot grant relief to Ms. Sumner’s request. Even if Ms. Sumner’s request was properly filed by Defendant Manderfield, it is deficient. There is no indication that Defendant has exhausted his administrative remedies. Pursuant to 18 U.S.C. § 3582(c)(1)(A), an imprisoned person may file a motion for compassionate release “after (1) exhausting the BOP’s administrative process; or (2) thirty days after the warden received the compassionate release request—whichever is earlier.” Jones, 980 F.3d at 1104–05 (citations omitted). Defendant has not exhausted the BOP’s administrative process. As such, the Court will not grant this motion for compassionate release. For the reasons set forth above, the Court DENIES Tia Sumner’s compassionate release request. (ECF No. 94.) IT IS SO ORDERED. Case 5:16-cr-20817-JEL-APP ECF No. 98, PageID.<pageID> Filed 10/22/25 Page 4 of 5
5 Dated: October 22, 2025 s/Judith E. Levy Ann Arbor, Michigan JUDITH E. LEVY United States District Judge CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was served upon counsel of record and any unrepresented parties via the Court’s ECF System to their respective email or first-class U.S. mail addresses disclosed on the Notice of Electronic Filing on October 22, 2025. s/William Barkholz WILLIAM BARKHOLZ Case Manager Case 5:16-cr-20817-JEL-APP ECF No. 98, PageID.<pageID> Filed 10/22/25 Page 5 of 5
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