United States v. Trenkler

Brief of the National Association of Criminal Defense Lawyers as Amicus Curiae in Support of Appellee.

Brief filed: 05/16/2022


United States v. Trenkler

1st Circuit Court of Appeals; Case No. 21-1444

Prior Decision

D. Mass. No. 92-cr-10369


NACDL’s amicus brief argues that sentencing errors can be an extraordinary and compelling reason for a reduction in sentence. Sentencing errors fit within the definition of “extraordinary” and “compelling.” The government’s argument conflicts with the First Circuit’s decision in United States v. Ruvalcaba and similar cases from other circuits. A motion for compassionate release is fundamentally different than a second habeas petition.


Jamesa J. Drake, NACDL Amicus Committee 1st Circuit Vice-Chair, Auburn, ME; Michael L. Waldman and Courtney L. Millian, Kramer Levin Robbins Russell, Washington, DC.

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