United States of America v. Manderfield

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
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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
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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.
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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.
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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
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