Compassionate Release After the First Step Act: What Justice-Impacted Individuals Need to Know

At A Better Tomorrow (ABT) Community, we often hear from incarcerated individuals and their families who are hoping compassionate release might provide a path home when serious medical or family circumstances arise. While compassionate release can offer relief in limited situations, recent court decisions show that it remains difficult to obtain—especially when claims are based on inadequate medical care in federal prison.

A recent Sixth Circuit decision, United States v. Williams, illustrates just how high the bar remains, even after reforms intended to expand access to compassionate release.¹

What Is Compassionate Release?

Compassionate release allows a federal court to reduce a person’s sentence when “extraordinary and compelling reasons” justify early release under 18 U.S.C. § 3582(c)(1)(A). Courts must also consider the sentencing factors listed in 18 U.S.C. § 3553(a), including public safety, deterrence, and whether the sentence remains “sufficient, but not greater than necessary.”

Before passage of the First Step Act of 2018, only the Bureau of Prisons (BOP) could file compassionate release motions. Because the BOP rarely did so, relief was uncommon and typically limited to prisoners who were terminally ill. The First Step Act changed that by allowing incarcerated individuals to file motions directly with the court after exhausting administrative remedies.

The Sentencing Commission’s 2023 Expansion

In 2023, the U.S. Sentencing Commission amended Guideline § 1B1.13 to clarify and expand what may qualify as “extraordinary and compelling reasons.” The updated guidance recognizes that compassionate release may be appropriate when:

• An incarcerated person has serious medical conditions requiring long-term or specialized care

• Necessary medical treatment is not being adequately provided in custody

• The lack of care creates a serious risk of health deterioration or death

• Certain family caregiving or abuse-related circumstances exist

  
  

These changes were intended to make compassionate release more accessible. However, as the Williams case demonstrates, courts continue to apply these standards narrowly.

The Case of United States v. Williams

Troy H. Williams was serving a lengthy federal sentence and suffered from serious blood-clotting disorders, including thrombophilia and recurrent deep vein thrombosis. These conditions required careful monitoring because he was prescribed warfarin, a blood-thinning medication that can become dangerous if not properly managed.

Williams argued that after being transferred to a different federal prison, his blood testing became inconsistent and delayed, placing him at serious medical risk. He filed a motion for compassionate release, claiming that the Bureau of Prisons was not providing adequate medical care as required under the Sentencing Commission’s updated guidance.

Both the district court and the Sixth Circuit Court of Appeals denied his request. In affirming the denial, the Sixth Circuit emphasized that although Williams’s medical conditions were serious, the medical records showed his condition remained stable and prison doctors stated they could manage his care. The court deferred to the Bureau of Prisons’ medical judgment and concluded that Williams had not demonstrated “extraordinary and compelling reasons” for release.¹

Why Courts Often Deny Medical-Based Requests

As discussed by Walter Pavlo in Forbes, the Williams decision reflects a broader pattern in compassionate release cases: courts are reluctant to second-guess prison medical staff unless there is clear, expert-backed evidence of inadequate care or imminent harm.²

Even under the expanded 2023 guidelines, incarcerated individuals must do more than show a serious diagnosis. They must demonstrate that the Bureau of Prisons cannot or will not provide necessary treatment and that this failure creates a substantial risk to their health. Without independent medical opinions or documented deterioration, courts typically side with prison officials.

What This Means for Incarcerated People and Families

For justice-impacted individuals, the takeaway is sobering. Compassionate release remains possible, but success requires strong documentation, a clear paper trail, and evidence showing real risk—not just disagreement with prison medical practices.

At ABT Community, we believe compassionate release is about dignity, humanity, and recognizing when continued incarceration no longer serves justice. While the First Step Act restored an important measure of judicial discretion, decisions like Williams show that relief remains the exception rather than the rule.

Moving Forward

Knowledge is power. Individuals considering compassionate release should document their medical care carefully, use administrative remedies to create records, and seek trusted support whenever possible. ABT Community remains committed to education, advocacy, and helping people navigate these complex systems—both during incarceration and after release.

This article is for educational purposes only and does not constitute legal advice.

References

1. United States v. Williams, No. 24-5278, ___ F.4th ___ (6th Cir. 2025).

2. Walter Pavlo, Compassionate Release Remains Difficult Despite Sentencing Guideline Changes, Forbes (2025).