Originally published July 8, 2020. Statements about the law were updated in October 2026; the box below gives today’s rules.
A compassionate release motion can help even when the judge says no to early release. In U.S. v. Ingram, a federal court in Ohio denied release but recommended moving the prisoner to a Residential Reentry Center (a halfway house) near his sick mother.
Most people ask for compassionate release to get out of prison early. But as this case shows, a court can also recommend other accommodations instead, and sometimes prisons then move people closer to home.
How courts look at extraordinary and compelling reasons
The First Step Act lets prisoners file for compassionate release themselves. Before, only the Bureau of Prisons (BOP) could file these motions, and prisoners had nowhere to turn once the BOP said no.
Now courts look at the criteria for compassionate release without the BOP. After a BOP denial, a prisoner can file directly with the court. As explained below, that gives prisoners more ways to improve their situation.
Possible grounds for compassionate release
Courts can release people who are at least 70 years old and have served at least 30 years in prison. These prisoners must not pose a risk to the community, and the BOP Director must confirm that.
Under 18 U.S.C. § 3582(c)(1)(A), a prisoner can also seek early release for “extraordinary and compelling reasons.” In that case, the BOP Director does not need to sign off. At the time of this case, courts generally required more than a chronic medical condition or a sick elderly relative.
Even if a court denies early release, it may still recommend accommodations. For example, the court can recommend moving a prisoner closer to a sick relative.
The motion in U.S. v. William Ingram
In U.S v. William Ingram, the United States District Court for the Southern District of Ohio ruled on a compassionate release motion. Mr. Ingram asked for early release under 18 U.S.C. § 3582(c)(1)(A), claiming “extraordinary and compelling reasons.”
After a child pornography conviction, Mr. Ingram violated the terms of his pretrial release. The court then sentenced him to 94 months in prison. He also had a 10-year suspended sentence. With less than a year left on his sentence, he asked for compassionate release.
Why he asked for early release
Mr. Ingram asked to be released early to care for his 93-year-old mother. She was in hospice with chronic kidney disease and multiple myeloma. He said she had no other relatives to help her.
The court rejected these reasons, finding they were not “extraordinary and compelling.”
What the court recommended instead
Mr. Ingram did not win early release, but he did improve the rest of his sentence. Although the court found his mother’s illness was not a strong enough reason for release, it took his wish to help his family into account.
The court recommended moving him to a Residential Reentry Center near his mother’s home. Without his motion, this accommodation might never have been considered.
In the end, he will serve his time at a residential facility closer to his sick mother. His motion improved the rest of his sentence, even without release.
Lessons from U.S. v. Ingram
U.S. v. Ingram shows the advantage of prisoners now filing compassionate release motions directly in court. Before the First Step Act, prisoners hit a brick wall when the BOP said no. Now courts hear directly from prisoners about their circumstances.
Prisoners should see a compassionate release motion as a tool. It lets you speak directly to a judge about your case. If nothing else, the court may improve your sentence in some other way.
Because courts may recommend accommodations instead of release, a petition should be prepared carefully. Avoid mistakes and put your strongest legal arguments in front of the court. An experienced attorney can make the legal process much easier to navigate.
Filing a compassionate release motion
Too often, prisoners don’t file compassionate release motions because they think the odds are against them and see it as a lost cause. U.S. v. Ingram shows that this isn’t always the case. A motion can bring a win for the prisoner even when early release is denied.
The biggest hurdle is showing “extraordinary and compelling reasons” for early release. At the time of this case, courts rarely released prisoners just because an aging family member was ill.
But prisoners close to the end of their sentence may receive helpful accommodations instead. That is because courts review the circumstances described in the motion. Prisoners might not otherwise get to paint this full picture for the court. In the past, the BOP decided whether the court would ever see a prisoner’s petition, or whether it would be denied outright.
Courts do not want to lower the bar for extraordinary reasons, but they can be sensitive to the hardships prisoners face. So they may be willing to support requests for transfers or facility changes. That may not be what a prisoner most wants, but it can still mean a real improvement in the conditions of the sentence.
How Criminal Center helps prisoners seek compassionate release
As you can see, a petition for compassionate release is a serious opportunity to reduce your sentence. Under the First Step Act, prisoners can now go to court when the BOP denies a petition. This part of the law is a major improvement, because it reduces the BOP’s control over who is granted early release.
Even when release is denied, a motion sometimes earns better accommodations. That is why it matters to have a lawyer prepare your petition. It could lead to a much more manageable prison sentence. Criminal Center represents federal prisoners seeking compassionate release across the country.
If you want help with a compassionate release request, book a consultation.